SEC Petition Evaluation Report 

Petition SEC-00046 

Report Rev # _ FINAL __ Report Submittal Date: _10-25-06__ 

Subject Expert(s): Albert W. Wolff , Bryce Rich, Leo Faust, Mel Chew, Steve Bump, Tim Adler 

Site Expert(s): N/A 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition Type Petition B Qualification Date DOE/AWE Facility Name 

SEC-00046 83.13 April 6, 2006 Feed Materials Production Center (FMPC) 

Petitioner Class Definition 

All employees and all subcontractors who worked at all locations at the Feed Materials Production Center (FMPC) in 

Fernald, Ohio, also known as the Fernald Environmental Management Project (FEMP), during the time period of January 

1, 1951 through December 31, 1989. 

Proposed Class Definition 

All employees of DOE, DOE contractors, or subcontractors who worked at all locations at the Feed Materials Production 

Center (FMPC) in Fernald, Ohio, also known as the Fernald Environmental Management Project (FEMP), from January 

1, 1951 through December 31, 1989. 

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status 

NONE 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

NONE 

ORAU Lead Technical Evaluator: Albert W. Wolff ORAU Review Completed By: Karin Jessen 

Peer Review Completed By: [Signature on file]

Mark Rolfes 

 11/03/06 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file]

Frank C. Crawford 

 11/03/06 

Date 

SEC Evaluation Approved By: [Signature on file]

Larry Elliott 

 11/03/06 

Date 
SEC-00046 FINAL Feed Materials Production Center (FMPC) 

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Evaluation Report Summary: SEC-00046, Feed Materials Production Center 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition 

Petition SEC-00046, qualified on April 6, 2006, requested that NIOSH consider the following class: 

All employees and all sub-contractors who worked at all locations at the Feed Materials Production 

Center (FMPC) in Fernald, Ohio, also known as the Fernald Environmental Management Project 

(FEMP), during the time period of January 1, 1951 through December 31, 1989. 

NIOSH-Proposed Class Definition 

Based on its research, NIOSH accepted the petitioner-requested class as defining a single class of 

employees for which NIOSH can estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all employees of DOE, DOE contractors, or subcontractors that worked at all 

locations at the Feed Materials Production Center (FMPC) in Fernald, Ohio, also known as the 

Fernald Environmental Management Project (FEMP), from January 1, 1951 through December 31, 

1989. 

Feasibility of Dose Reconstruction 

Per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it has access to sufficient 

information to: (1) estimate the maximum radiation dose incurred by any member of the class; or (2) 

estimate radiation doses more precisely than a maximum dose estimate. Information available from 

the site profile and additional resources is sufficient to document or estimate the maximum internal 

and external potential exposure to members of the proposed class under plausible circumstances 

during the specified period. 

Health Endangerment Determination 

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), NIOSH need not make a health endangerment 

determination, as it has determined that it has sufficient information to estimate dose for the members 

of the proposed class. 

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Table of Contents 

Evaluation Report Summary: SEC-00046, Feed Materials Production Center ...................................... 3
 

1.0 Purpose and Scope.......................................................................................................................... 9
 

2.0 Introduction .................................................................................................................................... 9
 

3.0 Petitioner-Requested Class/Basis and NIOSH-Proposed Class/Basis ......................................... 10
 

4.0 Data Sources Reviewed by NIOSH.............................................................................................. 11 

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 11 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures ..................................... 12 

4.3 Facility Employees and Experts .......................................................................................... 12 

4.4 Previous Dose Reconstructions ........................................................................................... 13 

4.5 NIOSH Site Research Database .......................................................................................... 13 

4.6 Radon and Cigarette Smoking Exposure Assessment of Fernald Workers ........................ 14 

4.7 Fernald Historical Records Database .................................................................................. 14 

4.8 Documentation and/or Affidavits Provided by Petitioners ................................................. 14
 

5.0 Radiological Operations Relevant to the Proposed Class ............................................................ 23 

5.1 FMPC Plant and Process Descriptions ................................................................................ 23 

5.2 FMPC Functional Areas ...................................................................................................... 24 

5.2.1 Uranium Hexafluoride to Uranium Fluoride Reduction ......................................... 25 

5.2.2 Sampling, Blending, and Assaying ......................................................................... 25 

5.2.3 Refining ................................................................................................................... 26 

5.2.4 Uranium Trioxide (UO3) to Uranium Fluoride (UF4) Conversion......................... 27 

5.2.5 Metals Production and Fabrication.......................................................................... 27 

5.2.6 Scrap Recovery........................................................................................................ 28 

5.2.7 Special Products ...................................................................................................... 28 

5.2.8 Waste Management ................................................................................................. 29 

5.2.8.1 Storage Silos .......................................................................................... 29 

5.2.8.2 Low-Level Radioactive Waste Pits ....................................................... 29 

5.2.9 Thorium Processing and Storage ............................................................................. 32 

5.2.10 Summary of Key FMPC Facilities .......................................................................... 35 

5.3 Radiological Exposure Sources from FMPC Operations .................................................... 38 

5.3.1 Alpha Particle Emissions......................................................................................... 38 

5.3.2 Beta Radiation Fields .............................................................................................. 39 

5.3.3 Neutron Exposures .................................................................................................. 40 

5.3.4 Photon Exposures .................................................................................................... 40 

5.3.5 Incidents and Fires................................................................................................... 41 

5.3.5.1 Thorium Blender Incident ..................................................................... 41 

5.3.5.2 Uranium Hexafluoride Gas Release ...................................................... 41
 

6.0 Summary of Available Monitoring Data for the Proposed Class ................................................. 42 

6.1 FMPC Internal Monitoring Data ......................................................................................... 44 

6.2 FMPC External Monitoring Data ........................................................................................ 49 

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7.0 Feasibility of Dose Reconstruction for the Proposed Class ......................................................... 51 

7.1 Pedigree of FMPC Data....................................................................................................... 51 

7.1.1 Internal Data Review............................................................................................... 52 

7.1.2 External Data Review.............................................................................................. 53 

7.2 Internal Radiation Doses at FMPC...................................................................................... 55 

7.2.1 Process-Related Internal Doses at FMPC................................................................ 56 

7.2.1.1 Urinalysis Information and Available Data........................................... 56 

7.2.1.2 Analysis of Coworker Bioassay Data.................................................... 57 

7.2.1.3 Other Types of Bioassay/Workplace Indicators .................................... 57 

7.2.1.4 Airborne Levels ..................................................................................... 57 

7.2.1.5 Other Radionuclides .............................................................................. 57 

7.2.2 Ambient Environmental Internal Radiation Doses at FMPC .................................. 59 

7.2.3 Internal Dose Reconstruction Feasibility Conclusion ............................................. 59 

7.3 External Radiation Doses at FMPC..................................................................................... 60 

7.3.1 Process-Related External Radiation Doses at FMPC .............................................. 60 

7.3.1.1 Radiation Exposure Environment.......................................................... 60 

7.3.1.2 History of Whole Body External Monitoring........................................ 61 

7.3.1.3 History of Extremity Monitoring........................................................... 62 

7.3.1.4 Neutron Dosimetry Study and Dose Reconstruction............................. 62 

7.3.1.5 Dosimetry Records ................................................................................ 62 

7.3.1.6 Application of Co-Worker Data for External Dose Reconstruction ..... 62 

7.3.2 Ambient Environmental External Radiation Doses at FMPC ................................. 62 

7.3.3 FMPC Occupational X-Ray Examinations ............................................................. 63 

7.3.4 External Dose Reconstruction ................................................................................. 63 

7.3.4.1 Photon and Beta Dose ........................................................................... 63 

7.3.4.2 Neutron Dose ......................................................................................... 64 

7.3.4.3 Unmonitored Individuals Working in Production Areas....................... 64 

7.3.4.4 Medical X-ray........................................................................................ 64 

7.3.5 External Dose Reconstruction Feasibility Conclusion ............................................ 65 

7.4 Evaluation of Petition Basis for SEC-00046 ....................................................................... 65 

7.4.1 Evaluation of Major Topics Detailed in Petition SEC-00046 ................................. 65 

7.4.1.1 Lack of Monitoring for Recycled Uranium (RU) Contaminants .......... 65 

7.4.1.2 Lack of Monitoring for Thorium........................................................... 66 

7.4.1.3 Lack of Monitoring for Radium and Daughters .................................... 67 

7.4.1.4 No Personnel or Area Monitoring for Neutrons .................................... 67 

7.4.2 Evaluation of Specific Petitioner Statements in SEC-00046 .................................. 67 

7.4.2.1 Respiratory Protection during K-65 Silo Processes .............................. 67 

7.4.2.2 Internal Dose Not Assigned from Bioassay or Air Monitoring ............ 68 

7.4.2.3 Fecal Sampling ...................................................................................... 68 

7.4.2.4 Falsification of Data .............................................................................. 68 

7.5 Other Issues Relevant to the Petition Identified During the Evaluation ............................. 69 

7.6 Summary of Feasibility Findings for Petition SEC-00046.................................................. 69
 

8.0 Evaluation of Health Endangerment for Petition SEC-00046...................................................... 69
 

9.0 NIOSH-Proposed Class for Petition SEC-00046 ......................................................................... 70
 

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10.0 References .................................................................................................................................... 71 

Tables 

Table 4-1: Number of FMPC Claims Submitted Under the Dose Reconstruction Rule ....................... 13
 

Table 5-1: FMPC Development Chronology ........................................................................................ 24 

Table 5-2: Key FMPC Facilities, Operations, and Dates of Operation ................................................. 35 

Table 5-3: FMPC Alpha-Emitting Radionuclides ................................................................................. 38 

Table 5-4: FMPC Beta-Emitting Radionuclides ................................................................................... 39 

Table 5-5: Default Photon Energies for FMPC Materials ..................................................................... 41
 

Table 6-1: Summary of HIS-20 Monitoring Data (1952-1983) ............................................................ 43 

Table 6.2: Number of In Vivo Measurements Performed Annually at the FMPC ................................ 46 

Table 6-3 Typical MIVRML1

 Counting Schedule at the FMPC in the 1970s ...................................... 48 

Table 6-4: FMPC Monitoring of Employees by Gender ....................................................................... 49 

Table 6-5: FMPC Dosimeter Characteristics ........................................................................................ 49
 

Table 7-1: Uranium Urinalysis Data Comparison ................................................................................. 52 

Table 7-2: External Data Comparison: FMPC ...................................................................................... 54 

Table 7-3: Comparison of Exposures Between Internal Correspondence and HIS-20 Database ......... 55 

Table 7-4: Summary of Feasibility Findings for SEC-00046 ............................................................... 69 

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SEC-00046 FINAL Feed Materials Production Center (FMPC) 

SEC Petition Evaluation Report for SEC-00046 

1.0 Purpose and Scope 

This report evaluates the feasibility of reconstructing doses for all employees and all subcontractors 

who worked at all locations at the Feed Materials Production Center (FMPC) in Fernald, Ohio, also 

known as the Fernald Environmental Management Project (FEMP), during the time period of January 

1, 1951 through December 31, 1989. It provides information and analyses germane to considering a 

petition for adding a class of employees to the Congressionally-created SEC. 

This report does not contain any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83, 

and the guidance contained in the Office of Compensation Analysis and Support’s Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004. 

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.1 

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose. 

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, NIOSH must also then determine whether there is a reasonable likelihood 

that such radiation doses may have endangered the health of members of the class. The regulation 

requires NIOSH to assume that any duration of unprotected exposure may have endangered the health 

of members of a class, when it has been established that the class may have been exposed to radiation 

during a discrete incident likely to have involved levels of exposure similarly high to those occurring 

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

1

 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 

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SEC-00046	 FINAL Feed Materials Production Center (FMPC) 

who were employed for at least 250 aggregated work days within the parameters established for the 

class or in combination with work days within the parameters established for other SEC classes. 

NIOSH is required to document its evaluation in a report, and to do so, relies on both its own dose 

reconstruction expertise as well as technical support from its contractor Oak Ridge Associated 

Universities (ORAU). Once completed, the report is provided to the petitioners and to the Advisory 

Board on Radiation and Worker Health (The Board). The Board will consider the NIOSH evaluation 

report, together with the petition, petitioner(s) comments, and other information the Board considers 

appropriate, in order to make recommendations to the Secretary of HHS on whether to add one or 

more classes of employees to the SEC. Once NIOSH has received and considered the advice of the 

Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary of HHS will 

make the final decision, taking into account the NIOSH evaluation, the advice of the Board, and the 

proposed decision issued by NIOSH. As part of this decision process, petitioners may seek a review 

of certain types of final decisions issued by the Secretary of HHS.2 

3.0 Petitioner-Requested Class/Basis and NIOSH-Proposed 

Class/Basis 

Petition SEC-00046, which qualified on April 6, 2006, requested that NIOSH consider the following 

class for addition to the SEC: All employees and all sub-contractors who worked at all locations at the 

Feed Materials Production Center (FMPC) in Fernald, Ohio, also known as the Fernald 

Environmental Management Project (FEMP), during the time period of January 1, 1951 through 

December 31, 1989. 

The petitioner provided information and affidavit statements to support the petitioner’s assertion that 

accurate dose reconstruction for the class is impossible due to radiation exposures not being 

monitored through personal or area monitoring, and that monitoring records were lost, falsified, or 

destroyed. In addition, the petitioner identified monitoring gaps cited in the Fernald Technical Basis 

Documents. NIOSH deemed the following petitioner statements and affidavits (italicized) sufficient 

to qualify SEC-00046 for evaluation: 

o	 There was no monitoring for internal exposures for recycled uranium contaminants. 

o	 There was no monitoring to detect transuranic contaminants with the Mobile In-Vivo 

Radiation Monitoring Laboratory. 

o	 Prior to 1989, there were no recycled uranium contaminants that were reported in analysis. 

o	 In vivo counts were not performed frequently enough to be of significant value in transuranic 

dose reconstruction. 

o	 There was no monitoring for non-uranium radionuclides. 

o	 Non-uranium urinalysis was not performed. 

o	 In vitro bioassays for thorium were not performed. 

o	 In the 1970s, during declassification efforts, thorium data was lost and a large number of 

records and files were destroyed. 

2 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas. 

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o	 Before 1989, smears or air sampling filters were not analyzed specifically for plutonium, 

neptunium, or thorium isotopes. 

o	 No records were found of any bioassay results for radium or daughter products during the 

time period identified in this evaluation. 

o	 There was no neutron dosimetry. 

o	 Air samples were manipulated to obtain desired readings and to give the appearance that 

radiation exposure levels were much lower than they actually were. 

The information and statements provided by the petitioner qualified the petition for further 

consideration by NIOSH, the Board, and HHS. The details of the petition basis are addressed below 

in Section 7.4. 

Based on its research, NIOSH accepted the petitioner-requested class as defining a single class of 

employees for which NIOSH can estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all employees of DOE, DOE contractors, or subcontractors who worked at all 

locations at the Feed Materials Production Center (FMPC), in Fernald, Ohio, also known as the 

Fernald Environmental Management Project (FEMP), from January 1, 1951 through December 31, 

1989. 

4.0 Data Sources Reviewed by NIOSH 

NIOSH identified and reviewed numerous data sources to obtain information relevant to determine the 

feasibility of dose reconstruction for the class of employees proposed for this petition. This included 

determining the availability of information regarding personnel monitoring, area monitoring, 

industrial processes, and radiation source materials. The following sections summarize the data 

sources identified and reviewed by NIOSH. 

4.1 Site Profile Technical Basis Documents (TBDs) 

A Site Profile provides specific information concerning the documentation of historical practices at 

the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external 

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

individual monitoring data. A Site Profile consists of an Introduction and five Technical Basis 

Documents (TBDs) that provide process history information, information on personal and area 

monitoring, radiation source descriptions, and references to primary documents relevant to the 

radiological operations at the site. As part of NIOSH’s evaluation here, NIOSH examined the 

following TBDs for insights into FMPC operations or related topics/operations at other sites: 

•	 Technical Basis Document for the Fernald Site – Introduction, ORAUT-TKBS-0017-1; Rev. 0; 

March 17, 2004 

•	 Technical Basis Document for the Fernald Site – Site Description, ORAUT-TKBS-0017-2; 

Rev. 0; May 20, 2004 

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•	 Technical Basis Document for the Fernald Site – Occupational Medical Dose, ORAUT-TKBS0017-3; Rev. 0; February 11, 2004 

•	 Technical Basis Document for the Fernald Site – Occupational Environmental Dose, ORAUTTKBS-0017-4; Rev. 0; February 7, 2006 

•	 Technical Basis Document for the Fernald Site – Occupational Internal Dose, ORAUT-TKBS0017-5; Rev. 0; May 28, 2004 

•	 Technical Basis Document for the Fernald Site – Occupational External Dose, ORAUT-TKBS0017-6; Rev. 0; April 20, 2004 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures 

An Oak Ridge Associated Universities (ORAU) Technical Information Bulletin (OTIB) is a general 

working document that provides guidance concerning the preparation of dose reconstructions at 

particular sites or categories of sites. An ORAU Procedure provides specific requirements and 

guidance regarding EEOICPA project-level activities, including the preparation of dose 

reconstructions at particular sites or categories of sites. NIOSH reviewed the following OTIBs and 

procedures as part of its evaluation: 

•	 OTIB: Dose Reconstruction from Occupationally Related Diagnostic X-ray Procedures, Rev. 03 

PC-1, ORAUT-OTIB-0006; Rev. 03, December 21, 2005 

•	 OTIB: Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium and Thorium 

Compounds,, ORAUT-OTIB-0024; Rev. 00, April 7, 2005 

•	 ORAUT-PROC-0060, Occupational Onsite Ambient Dose Reconstruction for DOE Sites;, 

Rev. 01; June 28, 2006 

•	 ORAUT-PROC-0061, Occupational X-ray Dose Reconstruction for DOE Sites, Rev. 01; July 21, 

2006 

4.3 Facility Employees and Experts 

Additional information was obtained by interviewing eight FMPC workers employed for at least some 

time during the 1951 to 1989 operational period. Interviewee selection was based on the worker’s 

willingness to be interviewed, as expressed at a Fernald retiree’s meeting held on May 9, 2006. The 

employee interviews ultimately included employees who worked in a wide range of FMPC areas. 

Information obtained during the employee interviews contributed to the general knowledge of FMPC 

and included information about radiological incidents the workers recalled, processing details and 

timelines, supervisory roles and responsibilities, exposure potential, contamination minimization 

efforts, and information about monitoring practices. 

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4.4 Previous Dose Reconstructions 

NIOSH reviewed its dose reconstruction database, NIOSH OCAS Claims Tracking System (NOCTS), 

to locate dose reconstructions under EEOICPA that might provide information relevant to the petition 

evaluation. Table 4-1 summarizes the results of this review for the period of January 1, 1951 through 

December 31, 1989. (Data available as of September 14, 2006) 

Table 4-1: Number of FMPC Claims Submitted Under the Dose Reconstruction Rule 

(January 1, 1951 through December 31, 1989) 

Description Totals 

Total number of claims submitted for energy employees who meet the proposed class definition 

criteria 

690 

Number of dose reconstructions completed for energy employees who were employed during the 

years identified in the proposed class definition 

619 

Number of claims for which internal dosimetry records were obtained for the identified years in the 

proposed class definition 

631 

Number of claims for which external dosimetry records were obtained for the identified years in the 

proposed class definition 

641 

NIOSH reviewed each claim to determine whether internal and/or external personal monitoring 

records could be obtained for the employee. The dose reconstruction claimant interviews provided 

some information that is useful for dose reconstruction, such as work locations, hours worked, 

incidents (such as fires, radioactive releases, and spills), and hazards encountered. Of the total 

number of claims submitted (690), 91% have internal monitoring data available and 93% have 

external monitoring data available. As of September 14, 2006, eleven (11) recent claims had not 

received a response from DOE for exposure records. 

4.5 NIOSH Site Research Database 

The NIOSH Site Research Database (SRDB) was reviewed for documents that would support the 

evaluation of the proposed class. As of October 4, 2006, 1,628 documents in the database were 

identified as pertaining to the FMPC site and were subsequently evaluated for their relevance to this 

petition. The documents that were identified include historical background on personnel dosimetry 

monitoring, air sampling records, radon and thoron sampling records, radon breath sample records, 

incident reports, and program descriptions (e.g., dosimetry department periodic report, dust sampling, 

air monitoring, environmental monitoring data, industrial hygiene reports, radiological control 

program, medical monitoring, process materials, and process descriptions). 

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4.6 Radon and Cigarette Smoking Exposure Assessment of Fernald Workers 

NIOSH reviewed the FMPC Radon Exposure Estimate Study conducted for NIOSH by Susan M. 

Pinney, et al, of the University of Cincinnati (Pinney 2004). This study adopted methods used by the 

Radiological Assessments Corporation for the Fernald Dosimetry Reconstruction Project to estimate 

offsite radon dose, and applied algorithms to the FMPC site to estimate worker exposure. This study 

also used a method to estimate worker location and shift schedule, in addition to calculating a 

bounding dose, in radon Working Levels, for all workers at the FMPC (Pinney 2004). 

4.7 Fernald Historical Records Database 

Using the eDesk database which is maintained by the DOE Environmental Management Consolidated 

Business Center and populated with re-typed reports as well as images of the original reports, a search 

for “thorium” was conducted. This search produced approximately 1,000 results that contained 

information on thorium processing at FMPC: including plants involved, health aspects of processing 

the material, air dust information, gamma dose rates from barrels, quantities, flowcharts, dates, etc. 

To date, approximately 60 of these reports have been received by NIOSH and are being uploaded into 

the SRDB. This is an ongoing process to support the revision of the FMPC Technical Basis 

Documents. Additional records are still being received. 

4.8 Documentation and/or Affidavits Provided by Petitioners 

In qualifying and evaluating the petition, NIOSH reviewed the following documents submitted by the 

petitioners (SECIS ID: 9362, received 12/12/2005; SECIS ID 9459, received 01-24-2006): 

•	 Industrial Case Study, Internal Memo from Dr. Quigley to Charles Dees, National Lead Company 

of Ohio (NLO); October 12, 1953; SECIS Ref ID: 9362, page 23 

•	 Questionnaire on Radiation Recordkeeping Systems at DOE/DOE Contractor Facilities, NLO 

response to DOE information request; June 29, 1984; SECIS Ref ID: 9362, page 26 

•	 Information on Forthcoming Feasibility Study on “Correlation of Lifetime Health and Mortality 

Experience of AEC and AEC Contractor Employees with Occupational Radiation Exposure”, 

NLO letter from J. A. Quigley to William Doran, USAEC; November 1, 1963; SECIS Ref ID: 

9362, page 33 

•	 Excerpt from GAO Testimony Protecting Department of Energy Workers’ Health and Safety, 

GAO/T-RCED-94-143, Page 7; March 17, 1994; SECIS Ref ID: 9362, page 37 

•	 Written Testimony for the Subcommittee on Immigration and Claims, Committee on the Judiciary, 

U.S. House of Representatives, Lisa Ledwidge, Institute for Energy and Environmental Research 

(IEER); September 21, 2000; SECIS Ref ID: 9362, page 40 

•	 Worker Radiation Dose Records Deeply Flawed, Arjun Makhijani and Bernd Franke, IEER; 

January 1998; SECIS Ref ID: 9362, page 48 

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•	 Health and Environmental Impacts of Nuclear Weapons Production, Arjun Makhijani, IEER; 

September 2000; SECIS Ref ID: 9362, page 57 

•	 Fernald Workers’ Radiation Exposure, Arjun Makhijani, IEER; March 1997; SECIS Ref ID: 

9362, page 64 

•	 Health Conditions in Various Plants, NLO Internal Memo from R. C. Heatherton to J. A. Quigley; 

March 6, 1953; SECIS Ref ID: 9362, page 70 

•	 Refinery NO2 Fume Releases, NLO Internal Memo from R. H. Starkey to J. A. Quigley; 

February 23, 1968; SECIS Ref ID: 9362, page 71 

•	 Standard Operating Procedure for the Collection of Air Dust Samples, K. Ross; 

December 23, 1960; SECIS Ref ID: 9362, page 73 

•	 Changes in Terminology, Absorption Factor, and Airborne Alpha Activity Limit, NLO Internal 

Memo from J. A. Quigley to J. H. Noyes; April 5, 1963; SECIS Ref ID: 9362, page 74 

•	 Testimony of Daniel J. Arthur Before The Subcommittee on Energy, Conservation and Power; 

August 12, 1986; SECIS Ref ID: 9362, page 76 

•	 Health Protection Appraisal, National Lead Company of Ohio; August 1972; SECIS Ref ID: 

9362, page 124 

•	 Memo and Report between Battelle and Robert W. Barber, Regarding Findings, Observations, and 

Recommendations Report, February 28, 1985; SECIS Ref ID: 9362, page 132 

•	 Comments on Draft Report of Health Physics Appraisal, October 7-10, 1980, Memo to B. J. Davis 

and K. Shank from R. C. Heatherton; November 24, 1980; SECIS Ref ID: 9362, page 138 

•	 Radiation from Thorium Materials, NLO Internal Memo from R.C. Heatherton to J. A. Quigley; 

April 19, 1955; SECIS Ref ID: 9362, page 140 

•	 Standard for Thorium-230, Letter from J. H. Noyes (NLO) to C. L. Karl, USAEC; August 17, 

1965; SECIS Ref ID: 9362, page 141 

•	 Memo from E. W. Goodpasture, the Vice Chairman for the Advisory Committee for Biology and 

Medicine to Mr. Gordon Dean, Chairman of the Atomic Energy Commission; Unknown Date; 

SECIS Ref ID: 9362, page 142 

•	 Letter from J. A. Quigley to John E. Bailey, National Lead Co., Monticello, Utah Concerning 

Uranium Absorptions; January 22, 1957; SECIS Ref ID: 9362, page 144 

•	 I. H. & R. Weekly Reports; Various Dates; SECIS Ref ID: 9362, page 146-157 

•	 I. H. & R. Monthly Report for October 1969; November 11, 1969; SECIS Ref ID: 9362, page 158 

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•	 Affidavit from Raymond L. Ruhe to the State of Ohio, Concerning falsification of sample results; 

February 2, 1993; SECIS Ref ID: 9362, page 161 

•	 Proposed Employer State Federal Records and Reports System for Radiation Workers, Excerpt 

from letter from unidentified sender to C. L. Karl, USAEC; July 11, 1966; SECIS Ref ID: 9362, 

page 165 

•	 Itinerary of Uranium from Time of Exposure until Time of Excretion in the Urine, Letter to the 

NLO Bio-assay Committee, J. A. Huesing; September 8, 1959; SECIS Ref ID: 9362, page 166 

•	 A Continued Program of Analysis for Uranium in Human and Animal Tissues, Excerpt, NLO, 

Richard Heatherton, Michael Boback, Joseph A. Quigley, M.D.; September 20, 1963; SECIS Ref 

ID: 9362, page 170 

•	 Letter to Herschel Hickman, Oak Ridge Operation Office from R. H. Moore, M.D. of the Hanford 

Environmental Health Foundation, Regarding an NLO possible autopsy study; July 11, 1979; 

SECIS Ref ID: 9362, page 172
 

•	 Response to Dosimetry Assessment Fact Sheet, NLO, Inc.; September 11, 1981; SECIS Ref ID: 

9362, page 174
 

•	 Preliminary Report, External Radiation Levels from Uranium and Thorium, Internal NLO Memo
 

from E. V. Barry to R. C. Heatherton; May 3, 1955; SECIS Ref ID: 9362, page 181
 

•	 Final Summary and Inventory of Thorium, Internal NLO Memo from J. Carvitti to P. N. 

McCreery; September 28, 1961; SECIS Ref ID: 9362, page 186
 

•	 Request for Authorization to Remove Thorium Residues from Inventory to Burial Ground, Letter 

from J. H. Noyes, NLO to C. L. Karl, USAEC; March 19, 1968; SECIS Ref ID: 9362, page 199
 

•	 Thorium NCG, Internal NLO Memo from R. H. Starkey to J. A. Quigley, M.D., July 6, 1964; 

SECIS Ref ID: 9362, page 201
 

•	 Health Protection Aspects of Thorium Production, Internal NLO Memo from M. W. Boback to 

R. C. Heatherton; March 8, 1976; SECIS Ref ID: 9362, page 203
 

•	 Radiation Levels of More Than 0.05% Thorium Residues, Internal NLO Memo from R. H. Starkey 

to J. Carvitti; October 12, 1956; SECIS Ref ID: 9362, page 207
 

•	 Air Dust Concentrations in the Pilot Plant Thorium Process; November 19, 1970; SECIS Ref ID: 

9362, page 208
 

•	 Air Dust Levels at Thorium Metal Operations; October 7, 1970; SECIS Ref ID: 9362, page 215
 

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•	 Monthly Thorium Inventory Position at NLO as of August 1, 1978, Letter from S. F. Audia, NLO, 

to H. Doran Fletcher, Oak Ridge Operations Office; August 10, 1978; SECIS Ref ID: 9362, page 

220 

•	 Thorium Processing at FMPC, Internal NLO Memo from J. O Davis to File #2; July 17, 1970; 

SECIS Ref ID: 9362, page 222 

•	 Annual Storage Inventory of Normal Uranium Concentrates and Thorium, Letter from J. H. 

Noyes, NLO to C. L. Karl, USAEC; June 25, 1968; SECIS Ref ID: 9362, page 226 

•	 Thorium Metal Production Housekeeping, Internal NLO Memo from K. N. Ross to J. E. 

Beckelhiemer; June 8, 1970; SECIS Ref ID: 9362, page 228 

•	 Ventilation for Redrumming of Thorium Residues, Request for Engineering Services from P. G. 

DeFazio to S. F. Audia; November 17, 1965; SECIS Ref ID: 9362, page 230 

•	 Thorium Operations at NLO – Present and Future, Excerpt from Letter from Unknown Author to 

C. L. Karl, USAEC; April 11, 1963; SECIS Ref ID: 9362, page 233 

•	 Thorium Operations - Pilot Plant, Internal NLO Memo from J. F. Wing to R. H. Starkey; July 17, 

1964; SECIS Ref ID: 9362, page 234 

•	 BeO Air Dust Evaluation of Plasma Flame Spray Facility – Pilot Plant, Internal NLO Memo from 

R. L. Bipes to R. H. Starkey; September 26, 1966; SECIS Ref ID: 9362, page 236 

•	 Sludge Furnace Alterations for Oxidation of Thorium Residues – Plant 6, Project Proposal CP-59­

79; October 20, 1959; SECIS Ref ID: 9362, page 239 

•	 Air Dust Evaluation of Thorium Furnace Operations, Plant 6, Memo to J. H. Carvitti from K. N. 

Ross; November 14, 1960; SECIS Ref ID: 9362, page 248 

•	 Thorium Turnings in Sylvania, Letter from J. H. Noyes, NLO, to C. L. Karl, USAEC; March 

1963; SECIS Ref ID: 9362, page 252 

•	 Air Dust Re-Evaluation of the Thorium Furnace-Plant 6, Memo to C. R. Chapman from R. H. 

Starkey, March 26, 1963; SECIS Ref ID: 9362, page 254 

•	 Meeting Held on Mach 10, 1970 to Discuss Cutting up of Thorium Derbies in Plant 6, Memo to 

Files from J. H. Cavendish; March 10, 1970; SECIS Ref ID: 9362, page 256 

•	 Monthly Report for February 1965, March 6, 1963; SECIS Ref ID: 9362, page 258 

•	 Survey of 3620 Operations, Internal NLO Memo from R. C. Heatherton to C. Chapman; October 

20, 1952; SECIS Ref ID: 9362, page 261 

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•	 Report on Overexposures, Internal NLO Memo from Dr. W. A. McClellan to Dr. J. A. Quigley; 

December 9, 1952; SECIS Ref ID: 9362, page 262 

•	 Air Dust Samples-Pilot Plant, Memo from J. O. Davis to R. C. Heatherton; May 29, 1953; SECIS 

Ref ID: 9362, page 264 

•	 Air Dust Evaluation-Pilot Plant, Memo to K. N. Ross from F. J. Klein; December 13, 1960; 

SECIS Ref ID: 9362, page 265 

•	 Attached Report-Air Dust Evaluation of Pilot Plant Reduction and Breakout Operations, Memo to 

J. O. Davis from R. H. Starkey; March 22, 1961; SECIS Ref ID: 9362, page 266 

•	 Major Injury #1, NLO Safety Guide; February 14, 1966; SECIS Ref ID: 9362, page 267 

•	 Major Injury #3 and #4, NLO Safety Guide; July 2, 1968; SECIS Ref ID: 9362, page 268 

•	 Health, Safety, and Environmental Matters at the Pilot Plant, Internal NLO Memo from R. M. 

Spenceley to E. M. Nutter; November 6, 1984; SECIS Ref ID: 9362, page 269 

•	 Control of Dust in the Sampling Plant, Internal NLO Memo from J. J. Costa to D. J. Blythe; 

August 25, 1953; SECIS Ref ID: 9362, page 270 

•	 Idea Letter, Ore Handling (Plant 1 – Plant 2), Excerpt of Letter from Unknown Sender to C. L. 

Karl, USAEC; November 11, 1960; SECIS Ref ID: 9362, page 271 

•	 Air Hygiene at Plant 2 Dumping Stations, Internal NLO Memo from C. E. Schumann to A. J. 

Stefanec; August 16, 1956; SECIS Ref ID: 9362, page 273 

•	 Re-Evaluation of Juice Hopper Filling Station, Plant 3; Memo; May 17, 1960; SECIS Ref ID: 

9362, page 274 

•	 Air Dust Evaluation of Hoffman Dumping Station-Plant II; Memo to G. Harr from K. N. Ross; 

December 30, 1960; SECIS Ref ID: 9362, page 275 

•	 Idea Letter, Dust Collection Facility for UO3 Milling and Loading Stations – Plant 3, Internal 

NLO Memo from P. G. DeFazio to J. H. Noyes; November 16, 1961; SECIS Ref ID: 9362, page 

276 

•	 Air Dust Results of Dumping Ore Concentrates; Memo to W. J. Adams from R. C. Heatherton; 

November 28, 1972; SECIS Ref ID: 9362, page 278 

•	 Refinery Uranium Exposures, Internal NLO Memo from J. A. Quigley to S. F. Audia; April 19, 

1972; SECIS Ref ID: 9362, page 279 

•	 Various Air Sampling Results or Evaluations including incidents such as fires; Various FMPC 

Locations and Dates; SECIS Ref ID: 9362, pages 280-293 

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•	 Cleaning Under Burnout Oxide Conveyors – Plant 5, Internal NLO Memo from F. J. Klein to R. 

H. Starkey; December 7, 1960; SECIS Ref ID: 9362, page 294 

•	 Air Contamination, Mill Area, Plant 6, Memo to G. Harr from R. C. Heatherton; March 15, 1955; 

SECIS Ref ID: 9362, page 297 

•	 Air Dust Survey-Plant 6 Machining Area; Memo to A. J. Stefanec from C. E. Schumann; April 15, 

1954; SECIS Ref ID: 9362, page 299 

•	 Dust Levels Encountered at Sludge Reactor, Plant 6; Memo to C. H. Bussert from J. F. Wing; 

August 12, 1958; SECIS Ref ID: 9362, page 303 

•	 Occupational Histories Relating to Urinary Excretion Levels, Internal NLO Memo from R. C. 

Heatherton to J. W. Durkin, M.D.; November 11, 1953; SECIS Ref ID: 9362, page 304 

•	 High Air Dust Exposure Operations; March 30, 1961; SECIS Ref ID: 9362, page 305 

•	 Air Dust Survey; Memo to J. A. Quigley from R. H. Starkey; October 30, 1961; SECIS Ref ID 

9362, page 306 

•	 Plant 7 Urine Sampling Program, Memo to J. A. Quigley from R. C. Heatherton; October 26, 

1954; SECIS Ref ID: 9362, page 307 

•	 Project Labor Pool Operations, Memo to J. A. Quigley from R. H. Starkey; April 24, 1964; 

SECIS Ref ID: 9362, page 309 

•	 Air Dust Evaluation of Thorium Reverter-Plant 8, Memo to R. H. Starkey from K. N. Ross; 

February 28, 1966; SECIS Ref ID: 9362, page 310 

•	 Fumes at Diuranate Furnace, Plant 8, Memo to A. J. Stefanec from R. L. Ruthe; April 9, 1957; 

SECIS Ref ID: 9362, page 312 

•	 Various Survey Data Memos, Various authors; Various dates; SECIS Ref ID: 9362, page 313-315 

•	 Exposure Study of Plant 8 Personnel to Airborne Radioactive Dust; Memo to S. F. Audia from H. 

M. Beers; October 5, 1967; SECIS Ref ID: 9362, page 316 

•	 Incident Observation Report, Regarding Dust Collector; October 24, 1967; SECIS Ref ID: 9362, 

page 318 

•	 Dust Sample Results with memo, Memo introduces the results; July 21, 1953; SECIS Ref ID: 

9362, page 319 

•	 Various Air Dust Memos, Various authors; Various dates; SECIS Ref ID: 9362, page 322-330 

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•	 Radioactively Contaminated Industrial Vehicles, Memo to R. H. Starkey from W. A. Smith; 

October 2, 1958; SECIS Ref ID: 9362, page 331 

•	 Review of Vehicle Contamination Survey Results, Memo to C. L. Karl from J. H. Moyes; 

September 25, 1961; SECIS Ref ID: 9362, page 333 

•	 Industrial Hygiene Evaluation of Industrial Truck Operator Job Assignments, Memo to J. A. 

Quigley from R. H. Starkey; April 11, 1969; SECIS Ref ID: 9362, page 335 

•	 Transfer of K-65 from Deteriorated to Solid Drums, Memo to W. Strattman from R. C. 

Heatherton; November 25, 1952; SECIS Ref ID: 9362, page 337 

•	 Cleaning Laundry Area, NLO Message Form; April 22, 1981; SECIS Ref ID: 9362, page 338 

•	 Health and Safety Division Monthly Report-July 1981, To R. M. Spenceley from R. C. 

Heatherton; July 31, 1981; SECIS Ref ID: 9362, page 339 

•	 Joint Task Force on Recycle Material Processing, Letter from R. M. Spenceley, NLO, to J. A. 

Reafsnyder, USAEC; May 1, 1985; SECIS Ref ID: 9362, page 341 

•	 POOS History and Risk Assessment, Excerpt from Westinghouse Internal Memo, S. L. Hinnefield 

to Distribution List; September 19, 1988; SECIS Ref ID: 9362, page 343 

•	 What National Lead Knew About Radiation in the 1950’s, Unknown Author; SECIS Ref ID: 9362, 

page 349 

•	 Radiation Hazards at Fernald, Unknown Author and Date ; SECIS Ref ID: 9362, page 350 

•	 IEER Qualifications, Unknown Source and Date; SECIS Ref ID: 9459, page 13 

•	 Addendum to the Report, “Release Estimates of Radioactive materials and Non-radioactive 

Materials to the Environment by the Feed Materials Production Center 1951-1985, Arjun 

Makhijani, Ph.D. and Bernd Franke; May 1989; SECIS Ref ID: 9459, page 14 

•	 Maximum Permissible Amounts of Radioisotopes in the Human Body and Maximum Permissible 

Concentrations in Air and Water, National Bureau of Standards Handbook 52, Pages 2 & 3; 

March 20, 1953; SECIS Ref ID: 9459, page 37 

•	 Report on the Annual Health Protection Review at National Lead Company of Ohio, USAEC Oak 

Ridge Operations Office Internal Memos from Herman M. Roth to C. L. Karl; July 15, 1964 and 

July 16, 1965; SECIS Ref ID: 9459, page 39 

•	 Report on Health Protection Review – National Lead Company of Ohio – April 1965, Letter from 

J. H. Noyes, NLO, to C. L. Karl, USAEC; June 16, 1965; SECIS Ref ID: 9459, page 48 

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•	 Health Protection Appraisals and Assessments, September 1968, September 1970, August 1972, 

October 1980, February 1985, and September 11, 1981; SECIS Ref ID: 9459, page 56 

•	 Urinary Uranium Investigations, Internal NLO Memo from W. S. Shurkin to R. C. Heatherton; 

May 13, 1955; SECIS Ref ID: 9459, page 64 

•	 Reporting Requirement for Internal Exposures, Letter from M. S. Nelson, NLO to C. L. Karl, 

USAEC; March 6, 1972; SECIS Ref ID: 9459, page 65 

•	 Internal Radiation Exposure Evaluation, Letter from R. M. Spenceley, NLO, to W. H. Travis, 

USAEC Oak Ridge Operations Office; August 1, 1979; SECIS Ref ID: 9459, page 67 

•	 Occupational Safety & Health Standards, Part 1910.86, Ionizing Radiation, Internal NLO Memo 

from R. C. Heatherton to D. L. Dunaway; October 19, 1972; SECIS Ref ID: 9459, page 69 

•	 Production Division Safety Meeting Minutes, NLO; Date Unknown; SECIS Ref ID: 9459, page 71 

•	 Letter, W. H. Travis to Multiple Addresses, 10/14/81, “Health Physics ALARA Goal Program”, 

Letter from R. M. Spenceley, NLO, to William H. Travis, NRC; November 25, 1981; SECIS Ref 

ID: 9459, page 72 

•	 Health Hazards Involved in Processing Thorium Materials, Internal USAEC Letter from W. B. 

Harris to R. L. Kirk; Date Unknown; SECIS Ref ID: 9459, page 74 

•	 Thorium at Fernald, Internal USAEC Letter from W. B. Harris to Merril Eisenbud; April 17, 

1956; SECIS Ref ID: 9459, page 78 

•	 Disposal of Fernald Thorium Production Residues, Internal USAEC Letter from C. L. Karl to S. 

R. Sapirie; August 22, 1958; SECIS Ref ID: 9459, page 79 

•	 MPC Values for Thorium, Internal NLO Memo from R. C. Heatherton and M. W. Boback to J. A. 

Quigley, M.D.; August 17, 1965; SECIS Ref ID: 9459, page 83 

•	 Contamination of Plant 3 Heater Tubes, Internal NLO Memo from R. C. Heatherton to W. C. 

Mill; October 26, 1954; SECIS Ref ID: 9459, page 86 

•	 Incident Involving Uranyl Nitrate Burn, Internal NLO Memo from Bio-Assay Committee to J. A. 

Quigley, M.D.; April 10, 1968; SECIS Ref ID: 9459, page 87 

•	 Plant 2 Refinery Uranium Exposures, Internal NLO Memo from J. A. Quigley, M.D. to S. F. 

Audia; April 19, 1972; SECIS Ref ID: 9459, page 89 

•	 Internal NLO Memo Regarding Plant 4 high airborne levels, from E. V. Barry to R. C. 

Heatherton; August 17, 1955; SECIS Ref ID: 9459, page 93 

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•	 Several documents and memos regarding chemical exposures and hazards; SECIS Ref ID: 9459, 

pages 94-106 

•	 Wrist Badge Exposures Using All-Plastic Badge in Plant 5, Internal NLO Memo from K. N. Ross 

to M. W. Boback; March 29, 1973; SECIS Ref ID: 9459, page 107 

•	 Chip Fires, Plant 5 East Ingot Saw, Internal NLO Memo from R. C. Heatherton to J. F. Schiltz; 

April 19, 1976; SECIS Ref ID: 9459, page 110 

•	 Internal NLO Memo from A. J. Stefanec to D. Nelson regarding external overexposures to 

operators in the “burnout” area; August 15, Year Unknown; SECIS Ref ID: 9459, page 111 

•	 Justification of Basic Need for Ventilation Systems in Machining Area Plant 6, Internal NLO 

Memo from S. F. Audia to P. G. DeFazio; June 18, 1954; SECIS Ref ID: 9459, page 112 

•	 Re-Evaluation of Scrap Melting Operation – Building 70, Internal NLO Memo from J. F. Wing to 

J. A. Quigley, M. D.; November 3, 1960; SECIS Ref ID: 9459, page 114 

•	 Chemicals in the Environment: Perchloroethylene; Prepared by U.S. Environmental Protection 

Agency; August 1994; SECIS Ref ID: 9459, page 117 

•	 Airborne Contamination-Plant 8, Memo to L. W. Kessler from J. A. Huesing; September 16, 

1957; SECIS Ref ID: 9459, page 118 

•	 Hand Packing “23” Material, Memo to Ross from A. D. Werkam; August 11, 1961; SECIS Ref 

ID: 9459, page 122 

•	 Unaccounted For Low Enriched Uranium – Plant 8, Letter from William T. Warner, USAEC to J. 

H. Noyes, NLO; July 14, 1964; SECIS Ref ID: 9459, page 123 

•	 Idea Letter – Revisions to UAP Furnace Facility – Plant 8, Letter from Unknown Sender to C. L. 

Karl, USAEC; December 12, 1966; SECIS Ref ID: 9459, page 124 

•	 Incident Observation Report, Emptying of Rotex Dust Collector No. 6018, Internal NLO 

Correspondence from C. W. Zimber to E. D. Leininger; September 10, 1968; SECIS Ref ID: 9459, 

page 125 

•	 Incident Observation Report, NPR Dust Collector, Internal NLO Correspondence from D. Jones to 

F. Klein; September 16, 1968; SECIS Ref ID: 9459, page 126 

•	 Job Order Request H-8519, Regarding Ventilation System Change, R. Wright; November 17, 

1971; SECIS Ref ID: 9459, page 127 

•	 Inter-Office Routing Slip, Regarding strong fumes; To J. A. Quigley; Date Unknown; SECIS Ref 

ID: 9459, page 128 

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• High Air Dust Exposure Operations; January 23, 1961; SECIS Ref ID: 9459, page 129 

5.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize the radiological operations at the Feed Material Production 

Center (FMPC) from October 1951 to July1989, and the information available to NIOSH to 

characterize particular processes and radioactive source materials. From available sources, NIOSH 

has gathered process and source descriptions, information regarding the identity and quantities of each 

radionuclide of concern, and information describing both the process through which the radiation 

exposures of concern may have occurred and the physical environment in which they may have 

occurred. The information included within this evaluation report is intended only to be a summary of 

the available information. Radiological operations are discussed in more detail in ORAU-TKBS0017-2, Technical Basis Document for the Fernald Environmental Management Project (FEMP) – 

Site Description. 

5.1 FMPC Plant and Process Descriptions 

The Feed Materials Production Center (FMPC) was a large-scale, integrated facility that produced 

uranium metal products (e.g., derbies, ingots, billets, and fuel cores) used as feed materials in U.S. 

Department of Energy (DOE) defense programs. The site production mission has ended and the site 

has been undergoing remediation and cleanup since 1989. The facility officially closed as a 

production facility in 1991 and DOE changed the facility’s name to Fernald Environmental 

Management Project (FEMP) to reflect the current mission of site cleanup and remediation. 

FMPC began operations as a pilot plant in 1951 and was fully operational by the end of 1954. 

FMPC’s primary function was to convert uranium ore concentrates and recycled materials into either 

uranium oxides or highly purified uranium ingots and billets for machining or extrusion into tubular 

forms of assorted uranium enrichment. These products were prepared for use as production reactor 

fuel cores and target fuel elements. In addition, small amounts of thorium were also processed on site. 

Uranium metal production peaked in 1960 at approximately 10,000 metric tons uranium (MTU). In 

1964, uranium metal production began to decline until it reached a low of approximately 1,230 MTU 

in 1975. Because of the decline in both demand from other sites and uranium metal production, DOE 

considered closing FMPC. From 1972 through 1979, the number of staff, which had peaked at 2,891 

in 1956, slowly declined from 662 to 538. In 1981, FMPC was directed to plan restoration of the site 

to accommodate projected product requirements approaching the original production capacity. 

Significantly increased production levels, a rapid staff buildup in many areas, and implementation of a 

major facilities restoration program followed. Accomplishments in the period from 1981 to1989 

included production output of three times the 1979 MTU level and a staff increase from 538 to more 

than 1,000. 

Production of uranium metal at FMPC ended in July 1989 when the focus turned to site cleanup 

efforts (ORAU-TKBS-0017-2). 

Table 5-1 summarizes the site development at FMPC. 

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Table 5-1: FMPC Development Chronology 

Years Buildings Comments Plant Population 

1951 – 1953 Pilot, 1, 2/3, 4, 5, 6, 8 Uranium production began. FMPC used 

approximately 400,000 square feet of floor 

space. 

Employment and production 

increased concurrently. 

There were 1,724 employees 

in 1953. 

1954 7, 9 FMPC was fully operational. 2,482 

1955-1956 K-65 Silos 1 & 2 FMPC reached full production. FMPC reached a peak 

employment of 2,891 

employees in 1956. 

1972 Pilot, 64, 65, 67 FMPC was designated as the DOE thorium 

material repository. 

662 

1979-1985 Pilot, 1, 2/3, 4, 5, 6, 8, 

and 9 

FMPC production ramped up again by a 

factor of three. 

FMPC employment increased 

from a low of 538 employees 

in 1979 to over 1,083 

employees in 1985. 

1989 All Facilities FMPC production operations ceased and 

FMPC became the Fernald Environmental 

Management Project. 

992 

Source for comparison: Cochran, 1987 

5.2 FMPC Functional Areas 

FMPC operations included the following functional areas: 

• Uranium Hexafluoride (UF6) to Uranium Fluoride (UF4) Reduction 

• Sampling, Blending, and Assaying 

• Refining 

• Uranium Trioxide (UO3) to Uranium Fluoride (UF4) Conversion 

• Metals Production and Fabrication 

• Scrap Recovery 

• Special Products 

• Waste Management 

• Thorium Processing and Storage 

The FMPC used a variety of chemical and metallurgical processes to support its primary mission of 

supplying metallic fuel cores to production reactors in Richland, Washington and Savannah River, 

South Carolina. In addition, the facility shipped some metal directly to DOE facilities in Oak Ridge, 

Tennessee and Rocky Flats, Colorado. 

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The first step in the FMPC production process was purification of uranium. In the early years, prior to 

1960, the site processed uranium ore, including pitchblende ore from the Belgian Congo, through a 

series of chemical processes. Later, it extracted uranium from scrap metal or recycled material (e.g., 

floor sweepings, dust from dust collectors, and production residues) received from onsite operations 

and other DOE complex sites. The uranium that was processed was depleted, natural, or slightly 

enriched with the average content close to natural isotopic ratios. Enrichments in raw materials 

ranged up to 20%; however, 2% enriched uranium was the highest enrichment processed in significant 

quantities (ORAUT-TKBS-0017-2, Section 2.1.3). 

FMPC uranium production began with ore concentrates, recycled uranium from spent reactor fuel, or 

from various uranium compounds that served as feed materials. Impure starting material was 

dissolved in nitric acid to produce a crude uranyl nitrate solution for solvent extraction purification. 

Purified uranyl nitrate solution was concentrated by evaporation and thermally denitrated to uranium 

trioxide, or orange oxide. Orange oxide was converted to uranium tetrafluoride, or green salt, for 

reduction to metal. In addition, green salt was produced from uranium hexafluoride received from 

other DOE sites. 

Uranium metal was produced by reacting uranium fluoride and magnesium metal in a refractory-lined 

reduction vessel. The uranium metal was shaped in forms called derbies, each weighing anywhere 

from 136 kg to 168 kg. This primary uranium metal was re-melted with scrap uranium metal to yield 

a purified uranium ingot that was extruded to form rods or tubes. Sections were cut and machined 

into necessary final dimensions. These machined cores were shipped to other DOE sites for canning 

and final assembly into reactor fuel elements. Since the late 1960s, all cylindrical ingots were centerdrilled at FMPC and sent off-site for extrusion. Most of the extruded tubes were returned to FMPC 

for heat treatment and final machining before they were shipped for use at other DOE sites. 

Periodically, small amounts of thorium were processed. In general, thorium production steps were 

similar to those followed in uranium production. Final products included purified thorium nitrate 

solution, solid thorium compounds, or metal. Since 1972, the FMPC served as the thorium materials 

repository for DOE. Approximately two-thirds of the material in the DOE repository was processed 

at the FMPC, with the remainder originating from other DOE facilities. 

Additional information regarding the functional areas of the FMPC can be found in ORAUT-TKBS0017-2. 

5.2.1 Uranium Hexafluoride to Uranium Fluoride Reduction 

Both the Pilot Plant and Plant 7 converted uranium hexafluoride to uranium fluoride in a gas-to-gas 

reactor. The uranium hexafluoride arrived in solid form in large cylinders and was first heated to form 

a gaseous compound and subsequently reduced to uranium fluoride. Radioactive sources related to 

this process were primarily uranium and “recycled uranium” that consisted of uranium hexafluoride 

and uranium fluoride powder with mixed enrichment from depleted to 2.5% uranium-235 by mass. 

5.2.2 Sampling, Blending, and Assaying 

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The sampling operation included a number of supporting operations. Several large-scale systems 

existed for crushing, grinding, and blending solid materials. These systems had a combined 

production capacity of more than 10 tons of solid material (uranium and thorium feed stocks) per 

hour. Major equipment included hammer mills, ring-roll mills, and falling stream samplers. Some of 

this equipment was shielded for handling radioactive materials. Special dust collecting and 

ventilating equipment permitted processing of toxic and radioactive materials. 

Enriched uranium slag and selected recycle materials were processed through a ring-roller mill for 

reuse in the production of uranium derby metal or for chemical processing to uranium trioxide in the 

refinery. The ring-roller mill could reduce particulate size to 95% minus 325-mesh at a rate of up to 

9.1 tons per day. A safe geometry digestion system helped to create safer processing of enriched 

uranium materials assaying from 5% to 20% uranium-235 at a rate of about 100 kg per shift. 

Primary radioactive isotopes encountered in the sampling, blending, and assaying functional area 

included depleted, natural, and enriched uranium compounds. Natural uranium exposure included 

pitchblende ore mined in the Belgian Congo. Because no processing was performed on this material 

before its receipt at the FMPC, it contained the equilibrium quantity of radium, thus requiring 

shielding against radiation during processing of the radium-bearing streams. In 1965, the FMPC 

became the official receiving station for uranium compounds of up to 5% uranium-235. In 1966, with 

the startup of enriched uranium operations in the refinery, more than 1,500 safe mass batches of up to 

10% uranium-235 feed materials were prepared for drum digestion. This recycled uranium was 

known to contain traces of neptunium-237, plutonium-238, and plutonium-239. In addition to the 

uranium sources, FMPC also received Canadian ores that contained thorium. Those ores began 

arriving in 1956 and reached large quantity levels by June 1957. 

Other facilities were available for opening fuel rods containing enriched ceramic oxide pellets and 

powder, reconditioning steel drums, and scrap metal baling. 

5.2.3 Refining 

Using nitric acid, recycle materials from various sources were placed into agitated tanks for digestion. 

The resulting slurry consisted of acid insolubles and a digest liquor of impure uranyl nitrate and 

excess nitric acid. Following a check for proper solution concentrations, the blended feed was 

pumped into the extraction system. Purified uranyl nitrate was recovered from the organic solvent 

stream by re-extraction with deionized water. This aqueous uranyl nitrate product, at a concentration 

of approximately 100 g/l uranium, was then denitrated. In the denitration process, through the use of 

forced convective evaporation and high-pressure steam boil, pure aqueous uranyl nitrate solution was 

concentrated down to approximately 1,350 g/l uranium. It was calcined in batches in nominal 1,900­

liter agitated denitration pots to yield uranium trioxide, the end-product of refinery operations. After 

milling, the uranium trioxide was packaged into hoppers, with each hopper containing approximately 

4.5 metric tons of uranium, or into 55-gallon drums. 

The radioactive materials that were handled and processed in the refining process included enriched 

recycled uranium. This recycled uranium was known to contain traces of neptunium-237, plutonium238 and plutonium-239. 

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5.2.4 Uranium Trioxide (UO3) to Uranium Fluoride (UF4) Conversion 

Mobile hoppers delivered orange oxide into stainless-steel fluid bed reactors, heated to approximately 

1,100o F. Dissociated ammonia entered the bottom of the reactors through a gas diffuser. The 

hydrogen and nitrogen held the uranium trioxide powder (orange oxide) in suspension. Partially 

converted uranium trioxide overflowed from the first fluid bed reactor into the second, completing the 

reaction with hydrogen. 

Hydrofluorination took place in groups of three heated horizontal ribbon-screw reactors arranged in 

vertical stacks. Uranium dioxide entered at one end of the top reactor and was conveyed slowly to the 

other end and stirred by a power-driven ribbon screw. The operating temperature grew progressively 

higher for each reactor, starting at approximately 300o F in the first and increasing up to 1,200o F in 

the third. Anhydrous hydrogen fluoride gas entered at the discharge end of the first and third reactors 

and flowed countercurrent to the powder flow. The result was a uranium fluoride product that 

weighed, blended, sampled for chemical analysis, and packaged in 38-liter cans for transportation to 

Plant 5 (metal production). 

The primary radioactive sources included in the uranium trioxide to uranium fluoride conversion 

process included uranium trioxide (orange oxide), ceramic oxide (brown oxide), and uranium 

tetrafluoride (green salt) powders. 

5.2.5 Metals Production and Fabrication 

To begin the reduction process that produces uranium metal, uranium fluoride and magnesium 

granules, totaling about 500 pounds, were blended and charged in a steel pot lined with magnesium 

fluoride slag. The pot was capped with slag to protect it from the intense heat of the reaction. The pot 

was fitted with a steel cover and heated in a resistance furnace to a temperature range of 1,200° to 

1,500o F for three to four hours, until the contents spontaneously reacted. At the point of reaction, the 

internal temperature of the pot might have reached 3,000o F. Approximately five minutes after the 

reaction occurred, the pot was removed from the furnace and stored in an air-cooling tank for at least 

one hour and then transferred to a water-cooling tank for several hours. After cooling, the contents 

were removed and the uranium mass, called a derby, was separated and cleaned using slag chipping 

hammers. 

Standard depleted production derbies weighed approximately 167 kg uranium. Enriched derbies 

weighed approximately 152 kg uranium. Most of the derbies were transferred to the Metals 

Production Plant casting area (Plant 6), some were sent to the Special Products Plant (Plant 9) casting 

area, and other derbies were sent to other DOE sites. 

All center-drilled and machined ingots and billets received at Plant 6 from the Special Products Plant 

were heat treated in a molten salt bath (50% NaCl, 50% KCl) at 1,350o F and water-quenched to 

achieve the beta phase grain structure for improving extrusion and final machining yields. Heattreated ingots and billets were extruded into tubular forms having varying inside and outside diameter 

dimensions. Extruded billets for the N-Reactor were fabricated at Hanford, while extruded tubes 

produced for the Savannah River Site were returned to the FMPC for target element core fabrication. 

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Radioactive sources in Plant 5 consisted of “uranium” and “recycled uranium” in the form of uranium 

fluoride granules, uranium metal derbies, billets and ingots, and uranium oxide in magnesium 

fluoride. Radioactive sources at Plant 6 included uranium and recycle uranium metal. 

5.2.6 Scrap Recovery 

The Scrap Recovery process (Plant 8) primarily involved upgrading enriched uranium recycle 

materials, from FMPC and other off-site operations, to produce feed materials for head-end processing 

in the refinery. Recycle materials containing metallic uranium or magnesium, oil, graphite, or other 

troublesome agents were heated to oxidize the components. Oversized pieces were screened and 

milled, and several furnaces (a rotary kiln, multiple-hearth vertical furnaces, and small single-hearth 

furnaces) were used to dry wet materials. 

All heated materials were used as feed material in the refinery. Recycle materials of significantly 

different isotopic assays were segregated throughout processing and in storage as well. The size of 

production equipment limited processing of enriched materials to 1.25% uranium-235. Filtration 

equipment was used to reclaim low-level solid waste for drying, packaging, and shipment for off-site 

burial. 

Radioactive sources in Plant 8 included uranium, recycled uranium metal, and thorium compounds. 

5.2.7 Special Products 

The Special Products Plant (Plant 9) was originally designed and constructed as a thorium metal 

production plant. An estimated 380 metric tons of thorium metal were produced in Plant 9 from 1954 

through 1955. Because thorium processing was infrequent and occurred in small amounts, the 

primary function of the Special Products Plant was changed from thorium processing to casting 

ingots, larger than those produced in Plant 5, as well as machining uranium metal pieces for extrusion. 

The principal tasks performed in the Special Products Plant were: 

• Casting enriched uranium derbies and recycle metal scrap into large-diameter ingots for the NReactor 

• Machining as-cast ingots and billets for extrusion 

• Cleaning depleted uranium derbies for off-site shipment 

• De-cladding un-irradiated copper-zirconium fuel cores 

Special Products plant operations primarily consisted of machining uranium metal pieces and casting 

enriched uranium ingots into sizes up to 13 inches in diameter and 25 inches in length, and weighing 

up to 900 kg. Shrinkage cavities and impurities were removed by cropping the top section, as was 

done with smaller ingots. 

Radioactive sources in the Special Products Plant included recycled uranium and uranium metal, as 

well as thorium metal and thorium compounds. 

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5.2.8 Waste Management 

The Waste Storage area outside of the production area included six low-level radioactive waste 

storage pits, two earthen-bermed concrete silos containing K-65 residues (high specific activity, lowlevel radium-bearing residues), one concrete silo containing metal oxides, and affected adjoining 

areas. It also included Waste Pits 1 through 6, the Clearwell, the solid waste (sanitary) landfill, as 

well as the burn pit between Pit 3 and Pit 4. The Southfield area (directly south of the FMPC plant 

area) contained construction rubble, a waste disposal area, and two fly ash piles. 

5.2.8.1 Storage Silos 

Four above-ground silos were constructed (Silos 1 through 4). While Silo 4 was never used, Silos 1, 

2, and 3 were used to store radium-bearing residues from uranium ore processing. 

Silos 1 and 2 (K-65 Silos) were above-ground silos used to store radium bearing residues, a byproduct 

of uranium ore processing. Silos 1 and 2 were made of cylindrical concrete and measured 88-feet in 

diameter and approximately 27-feet high. The silos were designed to load metal oxides in slurry form 

at a maximum rate of 8,000 gallons per day. In 1963, berms were constructed around each silo to 

provide lateral support to the silo walls; as a secondary benefit, the berms provided shielding. In 

1990, a protective coating was applied to the silos to minimize concrete deterioration and reduce 

radon emissions. A Radon Treatment System was added in 1987 to reduce the level of radon gas in 

the headspace above the residues. 

Silo 3 contained approximately 138,000 cubic feet of waste residues, known as cold metal oxides, 

which were generated during uranium concentrates extraction operations in the 1950s. The 

concentrates were received from a variety of uranium mills in the United States and abroad. The 

residues in Silo 3 were substantially different from those in Silos 1 and 2 (K-65). First, Silo 3 residues 

were dry (~10% moisture) while K-65 material were wet (~30% moisture). The Silo 3 material was 

calcined prior to storage and is now a fully oxidized fine powder. Second, while the Silo 3 

radiological constituents were similar to those in Silos 1 and 2, some radionuclides such as radium 

were present in much lower concentrations. The major fraction of metal impurities, including radium, 

was removed by the uranium mills prior to material being transferred to the FMPC site. Without the 

radium contribution, Silo 3 exhibited a much lower direct radiation field and radon emanation rate 

than Silos 1 and 2. 

While the K-65 silo area represented one of the most prevalent sources of gamma exposure at FMPC, 

the immediate concern involving Silo 3 was the risk of inhalation dose from suspended material 

following a release. Thorium-230, which is produced from the natural decay of uranium-238, had the 

largest specific activity (60 nCi/gm) in Silo 3. 

5.2.8.2 Low-Level Radioactive Waste Pits 

The Low-Level Radioactive Waste Pits in the Waste Storage Area covered approximately 37.7 acres 

and included Waste Pits 1, 2, 3, 4, 5, 6, the Burn Pit (also used for the disposal and burning of waste), 

and the solid waste (sanitary) landfill. The Southfield area (directly south of the FMPC plant area) 

contained construction rubble, a waste disposal area, and two fly ash piles. 

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Waste Pit 1 

Because waste slurries were filtered or calcined to remove water before they were placed into Pit 1, 

Waste Pit 1 was a dry pit. Pit 1 primarily received neutralized waste, filter cakes, vacuum-filtered 

sludge from production activities, magnesium fluoride slag, scrap graphite, and contaminated brick. 

In 1959, Waste Pit 1 was closed and covered with clean fill. Waste inventory records indicate that 

Waste Pit 1 contained 1,075 metric tons of uranium (Advanced Sciences, Inc. and ORAUT-TKBS0017-2). 

Waste Pit 2 

Waste Pit 2 was a dry pit that received primarily waste filter cakes, vacuum-filtered production 

sludge, magnesium fluoride slag, scrap graphite, contaminated brick, and concentrated raffinate 

residues. In 1964, Waste Pit 2 was closed and covered with clean fill. Waste inventory records 

indicate that Waste Pit 2 contained 175 metric tons of uranium (Advanced Sciences, Inc. and 

ORAUT-TKBS-0017-2). 

Waste Pit 3 

Waste Pit 3 was the first waste pit built specifically for settling solids from liquid waste streams. 

Primarily, it was used to hold lime-neutralized raffinate slurries and contaminated surface-water 

runoff. After Waste Pit 2 was filled, Waste Pit 3 received vacuum-filtered production sludge, 

neutralized liquid from process systems, neutralized refinery sludge, and cooling water from heat 

treatment operations. During the late 1960s, large quantities of neutralized residues from acid 

leaching of uranium-bearing magnesium fluoride slag were pumped into Waste Pit 3. In 1973, fill 

materials (including filter cake, slag leach residue, lime sludge, and fly ash) were placed in Waste Pit 

3 and construction activities were initiated to cover the waste with soil. Soil coverage was completed 

in 1977. Waste inventory records indicate that Waste Pit 3 contained 846 metric tons of uranium 

(Advanced Sciences, Inc. and ORAUT-TKBS-0017-2). 

Waste Pit 4 

Waste Pit 4 received solid wastes such as process residues (filter sludge, raffinates, graphite, 

magnesium fluoride slag, and pyrophoric uranium-bearing materials), scrap uranium metal, offspecification intermediate uranium products and residues, thorium metal and residues, and 

contaminated ceramics. Thorium metal and residues were placed in Waste Pit 4 when additional 

metal recovery was not economically feasible. Waste Pit 4 disposal activities were terminated in 1985 

and the pit closed in 1986. Also in 1986, cover activities were initiated. Waste inventory records 

indicate that Waste Pit 4 contained 2,203 metric tons of uranium and 74 metric tons of thorium 

(Advanced Sciences, Inc. and ORAUT-TKBS-0017-2). 

Waste Pit 5 

Waste Pit 5 was a settling basin for slurries, including neutralized raffinates, slurries from acid 

leaching of uranium-bearing slags, and sump slurries that were generally filtered to remove solids. 

Supernatant and sludge, produced by the co-precipitation of thorium wastes with barium carbonate 

and aluminum sulfate and the precipitation of uranium with calcium oxide, was disposed in Waste Pit 

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5. The discharge of slurried waste materials into Waste Pit 5 ended in 1983 and its use as a settling 

basin ended in 1987. Waste inventory records indicate that Waste Pit 5 contained 527 metric tons of 

uranium and 72 metric tons of thorium (Advanced Sciences, Inc. and ORAUT-TKBS-0017-2). 

Waste Pit 6 

Because Waste Pit 6 had a thin membrane liner that could be damaged by coarse materials, 

Waste Pit 6 received only non-coarse, non-pyrophoric materials (this excludes uranium and thorium in 

metallic form), which included magnesium fluoride slag, process residues, and filter cakes from 

vacuum filtering operations. In addition, the pit was used to store extrusion residue and heat treatment 

quench water. Use of Waste Pit 6 ended in 1985; it’s currently covered by water. Waste inventory 

records indicate that Waste Pit 6 contained 1,432 metric tons of uranium (Advanced Sciences, Inc. and 

ORAUT-TKBS-0017-2). 

Burn Pit 

The Burn Pit was initially excavated in 1957 to obtain clay for lining Pits 1 and 2. Subsequently, 

combustible materials, including pyrophoric and reactive chemicals, oils, and other low-level 

contaminated combustible materials, were burned in this pit. In addition, laboratory chemicals were 

discarded in the Burn Pit. In 1968, the Burn Pit was backfilled, and in 1984, all of the contents of the 

Burn Pit were transferred to Waste Pit 4 (EPA/ROD/R05-95/286, Advanced Sciences, Inc). 

Solid Waste (Sanitary) Landfill 

The solid waste (sanitary) landfill was located near the waste pits in the northwest corner of the Waste 

Storage Area and received non-burnable waste, non-radioactive waste, and non-radioactive 

construction rubble. The landfill was also known to contain small quantities of non-radioactive 

asbestos (Advanced Sciences, Inc. and ORAUT-TKBS-0017-2). 

Fly Ash Disposal Areas and Southfield 

The Fly Ash Disposal Areas are located southwest of the production area. Fly ash resulting from the 

coal-fired boiler plant was loaded into dump trucks and transported to the disposal area. Because fly 

ash dust was controlled by spreading oils containing uranium over the fly ash, about 1,000 kg of 

uranium was present in the Fly Ash Disposal Areas. 

The area known as the Southfield is assumed to be encompassed by the Disposal Areas due to the 

close proximity of those areas. The Southfield reportedly served as the repository for below-ground 

disposal of low-level radioactive construction rubble. 

Clear Well 

The Clear Well received surface runoff from the waste pits as well as some flow-through liquids. It 

was used as a final settling basin prior to runoff discharge into the Great Miami River. 

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5.2.9 Thorium Processing and Storage 

Periodically, small amounts of thorium (in comparison to the uranium output) were processed at 

FMPC. In the 1950s, thorium metal was produced for the nuclear aircraft program which was 

canceled in 1961. During the mid-1960s, thorium oxides were produced for the Light Water Breeder 

Reactor Program (Parsons, 1993). Purified thorium nitrate, to support various processes at the FMPC 

and other facilities, was produced from 1964 through 1979. All thorium processing at the FMPC 

ended in 1979. 

In general, thorium production steps were similar to those followed in uranium production. Thorium 

ore was dissolved, purified, and turned into a final product. The involvement of FMPC in thorium 

processing is described below. Final products included purified thorium nitrate tetrahydrate solution, 

solid thorium compounds, and metal. 

Starting in 1972, in addition to the processing of thorium, the FMPC served as DOE’s thorium 

materials repository. Approximately two-thirds of the material in the repository was processed onsite 

at FMPC. 

Pilot Plant 

Early thorium operations at the Pilot Plant included studies and demonstrations of thorium processes. 

From April through June of 1954, extraction studies of mantle grade thorium nitrate were performed. 

In addition, a project to demonstrate calcium reduction of thorium oxide to thorium metal powder 

took place during July 1956. Additionally, a unit was installed in April 1955 for the preparation of 

thorium oxalate pellets and thorium chloride. Later, a unit for the production of thorium chloride from 

thorium oxalate was installed in October 1955 and a project was initiated during July 1956 to 

demonstrate a process for calcium reduction of thorium oxide to thorium metal powder (Parsons, 

1993). No production data is available for the early Pilot Plant thorium processes (Dolan, 1988). 

From 1964 through 1979, thorium ores, crushed thoria pellets, thorium oxalate, as well as other 

thorium materials, were processed through the Pilot Plant thorium digestion system and extraction 

system to produce a purified thorium nitrate (TNT) solution to be used as feed for other thorium 

production streams. The TNT solution was also shipped as a final product to other facilities, including 

Nuclear Fuel Services, Weldon Springs, and Mallinckrodt. The digestion system consisted of a large 

tank into which the material to be digested had to be manually dumped. The digestion and extraction 

systems were used intermittently; some years the throughput rate was as high as one ton per day of 

purified TNT solution, in contrast to other years when the systems did not operate at all or operated 

sporadically. Production records indicate that 790.4 metric tons of thorium in the form of purified 

TNT solution was produced from 1966 to 1973. Production rates for other years are unavailable (Hill, 

1989). 

Using purified TNT solution as the feed material for the thoria gel process, the Pilot Plant was used to 

produce thoria gel from 1964 to 1970. Carbon dioxide and aqueous ammonia were added to the TNT 

solution to cause thorium hydroxide to precipitate from the solution. The thorium hydroxide was then 

slurried with water and aqueous ammonia, filtered on plate and frame filter, and then dried to form 

thoria gel (thorium hydroxide). This thorium hydroxide was then shipped to another location for 

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calcining and the final product was shipped to the customer. The total estimated production of thoria 

gel is estimated to be 686 metric tons (Hill, 1989). 

TNT crystal production occurred as a short term test in 1966. The process required the boiling of 

purified thorium nitrate tetrahydrate to a defined concentration. The resulting molten salt was then fed 

onto a conveyer where it crystallized and was drummed at the end of the conveyor. Total production 

during the test period was 425 kilograms of crystals (Hill, 1989). 

Thorium metal was produced in the Pilot Plant from 1969 to 1971. A modification of the process 

used in Plant 9 during the 1950s was employed in the Pilot Plant when zinc fluoride was used instead 

of zinc chloride for the reduction of thorium tetrafluoride to thorium metal; the metal quality was 

much improved by this change. In the process, thorium tetrafluoride was precipitated by adding 

hydrofluoric acid to the thorium nitrate tetrahydrate solution. The resulting thorium tetrafluoride was 

filtered, dried in a shelf pre-dryer, and re-dried in a furnace. The dried thorium tetrafluoride was then 

milled and blended with calcium metal and zinc fluoride and placed in a furnace to reduce the thorium 

tetrafluoride to thorium metal. The resulting zinc-thorium derby was cleaned, de-zinced, and sawed 

into the final product. Production records indicate that 809 derbies (51 metric tons) were produced by 

this process (Hill, 1989). 

From 1971 to 1976, thorium oxalate was produced by the Pilot Plant using a precipitation process 

where oxalic acid was added to a purified thorium nitrate tetrahydrate solution to form a wet 

precipitate which was filtered on a plate and frame filter. After filtering, the thorium oxalate solution 

was packaged and shipped to another location for calcining to thorium oxide. Production records 

indicate that 153 metric tons of thorium oxalate was produced (Hill, 1989). 

From 1977 to 1979, thorium nitrate was stabilized into thorium gel. This occurred when the need for 

thorium materials decreased to a level at which no other production was required. The process was 

similar to that used earlier to produce thoria gel. Production records indicate that 350 metric tons of 

thoria gel was produced by this process (Hill, 1989). 

Plant 1 

Beginning in 1956, Plant 1 processed Canadian ore, which contained thorium. Processing Canadian 

ore included crushing, grinding, and sampling the ore in preparation for further processing at the Pilot 

Plant. In addition to processing Canadian ore, Plant 1 supported sampling and analysis of material for 

on-site processes as well as that received from other sites. Some of this material would have 

contained thorium compounds. 

Plant 2/3 

In 1968, as a short-term thorium production test, Plant 2/3 was briefly used to produce thorium nitrate 

crystals and thorium oxide. While few details are available regarding this process, it is known that 

thorium nitrate crystals were produced in a denitration pot in Plant 2/3. Interviews with long-time 

employees suggest that crystal production was a short-term operation that likely amounted to the 

production of a single pot of crystals. Other FMPC records discuss the production of thorium oxide in 

Plant 2/3 by denitration, re-digestion, and drying (Hill, 1989). 

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Plant 4 

Plant 4 processed thorium oxide from Plant 9 into dried thorium tetrafluoride. The thorium 

tetrafluoride was then returned to Plant 9 and was used to produce thorium metal. This 

hydrofluorination process took place during 1954; and due to mechanical difficulties in the 

hydrofluorination Bank 7, occurred for only a short amount of time (Hill, 1989). 

Plant 5 

No known thorium activities occurred at Plant 5. 

Plant 6 

In 1959, in order to process pyrophoric thorium residues that were stored onsite and were the cause of 

numerous fires at FMPC, a proposal was made to perform alterations to the uranium sludge furnace in 

Plant 6 to allow for thorium oxidation (NLC, 1959). Thorium residues were oxidized in the Plant 6 

furnace from early 1960 to mid-1963. In 1970, thorium derbies were cut using a shear (Cavendish, 

1970). 

Plant 7 

No known thorium activities occurred at Plant 7. 

Plant 8 

Thorium hydroxide production occurred in Plant 8 for a six month period in 1966. Thorium 

tetrafluoride was reverted to thorium hydroxide by heating it in a reverter tube with hydrofluoric acid. 

Approximately 59 metric tons of thorium hydroxide was produced by this method (Hill, 1989). 

From 1969 to 1971, thorium residues were processed in Plant 8 converting the residues to thorium 

hydroxide before their return to the production stream. Residues were digested in hydrochloric acid 

and then filtered in a rotary vacuum filter. The filtrate was then precipitated and mixed with oxalic 

acid. This produced thorium oxalate which was then converted by a sodium hydroxide solution and 

filtered to produce thorium hydroxide. The resulting filter cake was then calcined in the uranium 

ammonium phosphate furnace and shipped to the Pilot plant digestion system. Approximately 310 

metric tons of thorium hydroxide was produced by this method (Hill, 1989). 

Plant 9 

Plant 9 was originally designed and constructed as a thorium metal production plant. Thorium was 

first introduced to the Plant 9 system on January 26, 1954. By February 15, 1954, thorium metal 

production operations began and continued through 1955, possibly into 1956, although production 

records are unavailable for 1956 (Parsons, 1988). The process began with the dissolution of solid 

thorium nitrate tetrahydrate (TNT) in nitric acid. Hydrofluoric acid was then added to the solution to 

precipitate a wet thorium tetrafluoride. The thorium tetrafluoride was then dried, pulverized, and 

blended with calcium metal and zinc chloride. This mixture was placed in a furnace to be co-reduced 

by the calcium to form a zinc-thorium derby which was then de-zinced and re-melted in a vacuum 

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furnace. This resulted in a 500 kilogram thorium metal ingot ready to be machined for the final 

product. The thorium chips and turnings that remained after the machining was completed were 

washed in nitric acid, dried, and then pressed into briquettes and returned to the production process to 

be re-melted. (Hill, 1989) 

In 1954, Plant 9 also produced thorium oxide from thorium nitrate tetrahydrate and oxalic acid. The 

thorium oxide was transported to Plant 4, hydrofluorinated to produce thorium fluoride, and then 

returned to Plant 9 to produce thorium metal. A total of 380 metric tons of thorium metal is estimated 

to have been produced in Plant 9 (Hill, 1989). 

Thorium Storage 

Starting in 1972, FMPC became DOE’s thorium materials repository. The stored materials were outof-specification production runs, process by-products, or excess materials returned from the 

downstream production facilities when the materials were no longer required (Parsons, 1993). As of 

1989, more than 13,000 containers of thorium (1,100 metric tons) compounds were stored onsite in 

Buildings 64, 65, 67, and the Pilot Plant. 

5.2.10 Summary of Key FMPC Facilities 

Table 5.2 summarizes the key FMPC processes, as well as the buildings and dates of operation. 

Table 5-2: Key FMPC Facilities, Operations, and Dates of Operation 

Buildings Key Facilities Dates of 

Operation 

Pilot Pilot Plant: In October 1951, the Pilot Plant became the first plant to operate. 

Initially it served as an operating prototype of all phases of FMPC’s uranium metal 

production process. Later, the principal functions included converting uranium 

hexafluoride into uranium tetrafluoride (green salt) for use in the metal production 

process and purifying and converting thorium nitrate solution into various thorium 

compounds. Primary radionuclides included uranium and thorium isotopes, 

including progeny. 

1951-1989 

1 Plant 1: The Sampling Plant supported operations throughout the site. Its principal 

capabilities were shipping, receiving, sampling, and storing large amounts of 

depleted, normal, and enriched uranium materials in open and covered storage 

areas; drying, crushing, milling, grinding, and classifying feed materials for 

processing; digesting enriched residues assaying 5% to 20% uranium-235 in 

geometrically safe equipment; and opening un-irradiated fuel pins containing 

enriched uranium dioxide pellets. Primary radionuclides included isotopes of 

uranium and thorium. 

1953-1989 

2/3 Plant 2/3: The Refinery converted the government stockpile of natural uranium ore 

concentrates to uranium trioxide. In 1962, site management placed Plant 2/3 on 

standby while refining operations were consolidated at the Weldon Spring site near 

St. Louis, Missouri. For the next few years, Plant 2/3 processed only scrap feed. 

Then in 1966, Plant 2/3 was reactivated following the shutdown of Weldon Spring. 

1953-1989 

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Table 5-2: Key FMPC Facilities, Operations, and Dates of Operation 

Buildings Key Facilities Dates of 

Operation 

In 1988, the refinery operated intermittently in a sequential campaign mode to 

convert enriched recycled materials to oxide. Primary radionuclides included 

isotopes of uranium and thorium. 

4 Plant 4: The Green Salt Plant produced green salt (uranium tetrafluoride) from 

uranium trioxide which was either produced in the refinery or recycled from other 

DOE sites. Due to a decline in demand, the facility operate sporadically from the 

early 1970s to 1980, when the process was restarted. Primary radionuclides 

included isotopes of uranium and some isotopes of thorium. 

1953-1989 

5 Plant 5: Using a thermite-type reaction with magnesium, the Metal Production 

Plant converted the uranium tetrafluoride that was produced in Plant 4 and the Pilot 

Plant into uranium metal. Primary radionuclides included isotopes of uranium. 

1953-1989 

6 Plant 6: At the Metals Fabrication Plant, uranium metal products were heat-treated 

to improve their strength and grain structure. Some of these products were shipped 

offsite for extrusion. The extruded tubes were returned to the Metals Fabrication 

Plant to be machined into final products for shipment to other DOE sites. Primary 

radionuclides included isotopes of uranium and thorium. 

1952-1989 

7 Plant 7: The Hexafluoride Reduction Plant converted uranium hexafluoride to 

green salt using the same process as the Pilot Plant. The green salt was used in 

Plant 5 to produce uranium metal. After only two years of operation, the U.S. 

Atomic Energy Commission (AEC) ordered the shutdown of Plant 7 because a 

similar processing plant was operating in Paducah, Kentucky. For the next 13 

years, site management considered several proposals for the idle facility, but none 

of the proposals were accepted. In 1969, all equipment was sold and the building 

was used to store drums of green salt and empty containers. Primary radionuclides 

included isotopes of uranium. 

1954 – 1956 

8 Plant 8: During the 1970s, Plant 8 operated on an as-needed basis. In Plant 8, 

recycled residues and scrap from uranium processing were upgraded before being 

sent to the refinery for uranium extraction. In addition to recycle functions, the 

plant equipment was used to treat enriched uranium residues. Primary 

radionuclides included isotopes of uranium and thorium. 

1953-1989 

9 Plant 9: The Special Products Plant was originally designed and constructed as a 

thorium metal production plant. Because thorium processing was infrequent and 

occurred in small amounts, the primary function of the Special Products Plant 

became casting larger ingots than those produced in Plant 5 and machining uranium 

metal pieces for extrusion. Primary radionuclides included isotopes of uranium and 

thorium. 

1954-1989 

Silos Silos 1 and 2: The K-65 Silos received radium-bearing residues from uranium ore 1955-2005 

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Table 5-2: Key FMPC Facilities, Operations, and Dates of Operation 

Buildings Key Facilities Dates of 

Operation 

processing. The K-65 ore was not processed prior to receipt, resulting in high 

levels of radium residue. Primary radionuclides included radium and radium 

progeny. 

Silo 3: In the 1950s Silo 3 received waste residues, known as cold metal oxides, 

which were generated during extraction operations involving uranium concentrates. 

The residues in Silo 3 are substantially different from those in Silos 1 and 2. First, 

Silo 3 residues are dry (~10% moisture) while K-65 material is wet (~30% 

moisture). Second, while Silo 3’s radiological constituents are similar to those in 

Silos 1 and 2, some radionuclides such as radium are present in much lower 

concentrations. 

Silo 4: Never used 

Waste Pits Pit 1: Waste Pit 1 received neutralized waste filter cakes, production plant sump 

cakes, depleted slag, scrap graphite, contaminated brick, and sump liquor. Most 

waste was dry. Primary radionuclides include isotopes of uranium. 

1952-1957 

Pit 2: Waste Pit 2 received dry, low-level radioactive wastes similar to Pit 1. 

Primary radionuclides include isotopes of uranium and thorium. 

1957-1964 

Pit 3: Waste Pit 3 operated as a settling basin, receiving wet waste streams 

consisting of lime-neutralized radioactive raffinate from the recovery plant (Plant 

8) and the general sump. Primary radionuclides include isotopes of uranium and 

thorium. 

1959-1968 

Pit 4: Waste Pit 4 primarily received dry, low-level radioactive waste such as 

process residues, trailer cakes, slurries, raffinates, graphite, non-combustible trash, 

and asbestos. Primary radionuclides include isotopes of uranium and thorium. 

Almost 75% of the thorium waste is in this pit. 

1960–1986 

Pit 5: Waste Pit 5 received liquid slurries similar to those in Pit 3 from the 

Refinery (Plants 2/3) and the Recovery plant (Plant 8). Primary radionuclides 

include isotopes of uranium and thorium. 

1968-1983 

Pit 6: Pit 6 received dry, solid, non-pyrophoric waste such as green salt, filter 

cakes, and process residues. Primary radionuclides include isotopes of uranium. 

1979-1985 

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Table 5-2: Key FMPC Facilities, Operations, and Dates of Operation 

Buildings Key Facilities Dates of 

Operation 

Burn Pit: The Burn Pit was used to dispose of laboratory chemicals and to burn 

pyrophoric and reactive chemicals, oils, and other low-level mixed combustible 

materials. No radioactive inventory is available. However, it likely that the Burn 

Pit contains both uranium and thorium. 

1957-1968 

Note: Information for this table was obtained from Remedial Investigation of the Feed Material Production Center— 

Part 1: Evaluation of Current Situation by Advanced Sciences, Inc. and from the DOE Fernald Closure Project 

website. 

5.3 Radiological Exposure Sources from FMPC Operations 

Radiation exposure at FMPC came from both internal and external sources. Although the primary 

isotope of interest was uranium, there were significant exposure potentials from the uranium progeny, 

especially radium. Due to the nature of processing activities at FMPC, there were significant 

opportunities for airborne exposure to uranium and thorium. The uranium, thorium, and associated 

progeny gave rise to alpha, beta, and photon exposures. Although neutron exposure is not normally a 

hazard associated with uranium, some compounds of uranium, such as uranium fluoride, can emit 

neutrons. 

5.3.1 Alpha Particle Emissions 

The primary alpha particle-emitting isotopes at FMPC were derived from uranium, thorium, and their 

progeny. Additional alpha-emitting radionuclides were introduced when FMPC accepted “recycled” 

uranium. The recycled uranium also contained transuranic contamination. Table 5-3 shows the alphaemitting nuclides and their primary alpha energies. 

Table 5-3: FMPC Alpha-Emitting Radionuclides 

Isotope Energy (MeV) 

Uranium-234 4.72(28%), 4.77(72%) 

Uranium-235 4.37(18%), 4.4(57%), 4.58(8%) 

Uranium-236 4.44((24%), 4.49(76%) 

Uranium-238 4.15(25%), 4.2(75%) 

Thorium-232 3.95(24%), 4.01(76%) 

Thorium-230 4.62(24%), 4.68(76%) 

Thorium-228 5.34 (28%), 5.43(71%) 

Thorium-227 5.76(21%), 5.98(24%), 6.04(23%) 

Radium-226 4.6(6%), 4.78(95%) 

Radium-224 5.45(6%), 5.68(94%) 

Radium-223 5.61(26%), 5.71(54%), 5.75(9%) 

Radon-222 5.49 

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Table 5-3: FMPC Alpha-Emitting Radionuclides 

Isotope Energy (MeV) 

Radon-220 6.29 

Radon-219 6.42(8%), 6.55(11%), 6.82(81%) 

Protactinium-231 4.95(22%), 5.01(24%), 5.02(23%) 

Actinium-227 4.86(0.18%), 4.95(1.2%) 

Bismuth-213 5.55 (0.16%), 5.87 (2%) 

Bismuth-211 6.28(16%), 6.62(84%) 

Polonium-218 6.0 

Polonium-216 6.78 

Polonium-215 7.38 

Polonium-214 7.69 

Polonium-212 8.78 

Polonium-211 7.45(99%) 

Polonium-210 5.305 

Astatine-218 6.65(6%), 6.7(94%) 

Plutonium-238 5.46(28%), 5.50(72%) 

Plutonium-239 5.11(11%), 5.16(88%) 

Plutonium-240 5.12(24%), 5.17(76%) 

Americium-241 5.44(13%), 5.49(85%) 

Neptunium-237 4.78(75%), 4.65(12%) 

5.3.2 Beta Radiation Fields 

As with the alpha emitters, the majority of the beta exposure came from uranium, thorium, and their 

progeny. In addition, when recycled uranium was introduced, technetium-99 and transuranics were 

also introduced. Table 5-4 shows the FMPC beta-emitting radionuclides and the corresponding 

maximum beta energy in units of MeV. 

Table 5-4: FMPC Beta-Emitting Radionuclides 

Isotope Maximum Beta Energy (MeV) 

Thorium-234 0.103(21%), 0.193(79%) 

Thorium-231 0.140(45%), 0.220(15%), 0.305(40%) 

Protactinium-234m 2.29(98%) 

Protactinium-234 0.53(66%), 1.13(13%) 

Actinium-227 0.043 

Actinium-228 1.18(35%), 1.75(12%), 2.09(12%) 

Francium-223 1.15 

Radium-228 0.055 

Bismuth-214 1.0(23%), 1.51(40%), 3.26(19%) 

Bismuth-212 1.55(5%), 2.26(55%) 

Bismuth-211 0.6(0.28%) 

Bismuth-210 1.161 

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Table 5-4: FMPC Beta-Emitting Radionuclides 

Isotope Maximum Beta Energy (MeV) 

Lead-214 0.65(50%), 0.71(40%), 0.98(6%) 

Lead-212 0.346(81%), 0.586(14%) 

Lead-210 0.016(85%), 0.061(15%) 

Thallium-208 1.28(25%), 1.52(21%), 1.80(50%) 

Thallium-207 1.44 

Technetium-99 0.292 

Plutonium-241 0.021 

5.3.3 Neutron Exposures 

There were no documented neutron exposures at FMPC. However, the use of uranium hexafluoride 

and uranium fluoride can generate neutrons through an alpha-neutron reaction between the uranium 

and the fluorine. Neutrons can also arise from higher enriched uranium. The Technical Basis 

Document for the Fernald Environmental Management Project (FEMP) – Occupational External 

Dose provides specific neutron factors to be used with photon exposures at FMPC. This particularly 

applies to the Pilot Plant, Plant 4, and associated warehouses. 

5.3.4 Photon Exposures 

When operational, FMPC was a large integrated facility that produced uranium metal products used as 

feed materials in DOE defense program facilities throughout the United States. FMPC utilized a 

number of processes that involved a variety of forms of uranium, including uranium ore concentrate, 

uranium hexafluoride, and recycled uranium scrap. The products were “variously sized, highly 

purified uranium metal forms of assorted standard isotopic assays” ranging from depleted to slightly 

enriched uranium metal products (ORAU-TKBS-17-06). The primary facilities, referred to as plants, 

are described in detail in Technical Basis Document for the Fernald Environmental Management 

Project (FEMP) – Site Description. The radiological hazards associated with these processes and 

products resulted from the radioactivity of uranium, thorium, and their daughter products, and in some 

instances, impurities in the recycled material. 

Many activities took place during FMPC’s period of operation. Throughput of material varied 

considerably, as did the sources of feed materials, one of which was ore from the Belgian Congo. 

That ore, pitchblende, contained large quantities of radium that required shielding. Wastes from this 

process were stored on the site in the K-65 silos. These silos also received waste from a site near 

Niagara Falls, New York. The silos became a large contributor to site background dose rates. 

As seen in Table 5-5, the processing of thorium at FMPC resulted in a higher energy photon mix than 

that resulting from uranium decay chains alone. Pitchblende processing also resulted in a high-energy 

gamma component in the K-65 silos. 

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Table 5-5 summarizes default photon energies for FMPC materials. 

Table 5-5: Default Photon Energies for FMPC Materials 

Energy Thorium Enriched Uranium Depleted Uranium Radium and Decay Chain 

<30 keV 0% 0% 0% 0% 

30-250 keV 16% 100% 50% 0% 

>250 keV 84% 0% 50% 100% 

5.3.5 Incidents and Fires 

A review of FMPC operating history revealed that a number of fires and small explosions resulted 

from working with uranium and thorium metal, especially when molten metal, stored un-oxidized 

metal turning or scraps, or phosphorus and magnesium compounds were involved. Interviews with 

former FMPC workers, including fork truck operators tasked with moving burning drums of uranium, 

reinforced that small fires and explosions occurred frequently, perhaps even daily at times. The 

majority of these incidents resulted in only local contamination. Other incidents mentioned by 

interviewees included ventilation exhaust system filter bag breaches, high dust levels from certain 

operations, and spills from drums of uranium ore. 

There were two serious incidents that had the potential to result in significant personnel exposure: a 

thorium blender incident and a uranium hexafluoride gas release. 

5.3.5.1 Thorium Blender Incident 

On March 15, 1954, operators were attempting to blend a batch of thorium fluoride, calcium metal, 

and zinc chloride as a preparatory step to making thorium metal. During the process, which had been 

delayed repeatedly, an explosion and fire occurred. The fire resulted in the death of two operators. 

Several other workers in the vicinity received minor burns either from the initial fire or from 

providing assistance to injured operators. 

The explosion spread material over a large area of Plant 9. An analysis of the event found that over 

50 pounds of thorium were unaccounted for. This material was most likely volatilized and could have 

resulted in significant airborne contamination of the event site (Noyes, 1954). 

5.3.5.2 Uranium Hexafluoride Gas Release 

On February 16, 1966, a major release from a 10-ton cylinder of uranium hexafluoride occurred in the 

Pilot Plant as operators attempted to initiate the uranium hexafluoride-to-uranium fluoride reduction 

process. Based on NIOSH’s investigation of the incident, it appears that the pigtail portion of the 

valve broke, causing an un-isolable break in the container. The operator attempting to open the 

cylinder was engulfed in a cloud of uranium hexafluoride. Emergency actions were initiated. After 

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approximately one hour, when the pressure in the cylinder dropped to the point that it could be 

plugged, the release was controlled. 

The operator engulfed in the uranium hexafluoride was hospitalized with pulmonary edema. He was 

released a few days later and returned to work on February 23, 1966. Other Pilot Plant personnel were 

given prophylactic oxygen inhalations and released to return to work (AEC, 1966). 

6.0 Summary of Available Monitoring Data for the Proposed Class 

Historically, the main purpose of the radiation monitoring programs at FMPC was to ensure that 

worker exposures to radiation were kept below the annual prescribed occupational exposure limits in 

effect at that time. The initial health and safety organization (the Industrial Hygiene and Radiation 

Division) at FMPC was organized and directed by an occupational medical physician and staffed 

primarily with industrial hygienists. Because of similar radiation safety issues associated with the 

facility’s uranium processing, the FMPC staff worked with Y-12 plant staff in Oak Ridge, Tennessee, 

to optimize program design and execution. 

FMPC’s radiological monitoring program was in place at the beginning of FMPC operations (1951) 

and included internal and external monitoring of personnel, as well as workplace and environmental 

monitoring. Individual doses from personnel dosimeters, urine samples, and in vivo analyses are 

available. Air monitoring and radiological survey results were well documented (and are available) in 

numerous FMPC reports (see Section 4.0). 

Similar to other DOE facilities, the percentage of the FMPC worker population included in the 

personnel monitoring programs varied over time. FMPC monitoring practices reflect a focus on 

monitoring those workers with the highest likelihood of exposure. Thus, the FMPC monitoring 

program coverage was especially comprehensive as evidenced by the review of the FMPC claims for 

dose reconstruction that have been logged in the NIOSH OCAS Claims Tracking System (NOCTS). 

This review (see Subsection 4.4) revealed that of the 690 individual claims in NOCTS, internal 

monitoring data are available for 91% of the claimants and external monitoring data are available for 

93% of the claimants. 

The primary repository of FMPC monitoring data is managed for DOE by their site management 

contractor (currently Fluor-Daniel). As at other DOE sites, monitoring results were documented via 

hard-copy radiation exposure records and in memoranda for the earlier time frame. In later years, 

monitoring results were recorded directly into databases. Some, though not all, of the earlier hard 

copy data has been entered into the “Health Information System” electronic database (known as HIS20). Not-yet-entered hard copy monitoring data are maintained in a secure filing system. A summary 

of data contained within the HIS-20 database is presented in Table 6-1. 

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Table 6-1: Summary of HIS-20 Monitoring Data (1952-1983) 

Urinalysis External Monitoring 

Year 

# of 

Records 

# of Employees 

Monitored 

# of 

Records 

# of Employees 

Monitored 

1952 288 72 1,158 1,154 

1953 2,436 753 1,742 1,739 

1954 8,724 1,392 2,438 2,437 

1955 10,669 1,982 2,668 2,662 

1956 11,314 2,514 2,890 2,883 

1957 13,581 2,990 2,704 2,699 

1958 9,992 2,542 2,373 2,366 

1959 14,549 2,655 2,398 2,392 

1960 19,386 2,709 2,438 2,433 

1961 9,505 2,443 2,507 2,502 

1962 8,486 2,191 2,206 2,201 

1963 9,673 2,041 2,063 2,058 

1964 6,748 1,919 1,979 1,977 

1965 6,561 1,680 1,665 1,659 

1966 6,379 1,660 1,636 1,634 

1967 5,359 1,674 1,620 1,618 

1968 4,607 1,423 1,542 1,540 

1969 3,217 1,321 1,255 1,251 

1970 3,081 1,126 972 972 

1971 2,234 884 768 767 

1972 2,207 686 555 553 

1973 2,748 790 602 601 

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Table 6-1: Summary of HIS-20 Monitoring Data (1952-1983) 

Urinalysis External Monitoring 

Year 

# of 

Records 

# of Employees 

Monitored 

# of 

Records 

# of Employees 

Monitored 

1974 2,508 712 579 576 

1975 2,293 718 569 565 

1976 2,045 709 541 528 

1977 1,853 681 524 493 

1978 1,666 655 500 464 

1979 1,534 634 484 445 

1980 1,566 652 515 459 

1981 2,125 742 3,782 700 

1982 2,095 266 5,306 914 

1983 3,381 977 6,147 1,026 

6.1 FMPC Internal Monitoring Data 

The following information provides a general summary of the FMPC internal monitoring program, as 

well as the types, quantity, and quality of the resulting data that can be used for internal dose 

reconstruction. Details regarding the various analyses used and the associated minimum detectable 

activities are presented in Technical Basis Document for the FMPC-Occupational Internal Dose 

(ORAU-TKBS-0017-5). 

A radiological control program was in place from the start of FMPC operations. The internal dose 

control sampling program consisted of the following: 

•	 Routine air sampling was used in all plants and operational processing areas to evaluate internal 

exposure potential via inhalation and served as the primary means of controlling intakes. This 

sampling was performed over the entire operational period evaluated in this report, from the start 

of FMPC operations through 1989 (ORAUT-TKBS-0017-5). 

•	 Urine samples were submitted after at least a two-day work break to allow elimination of uranium 

cleared rapidly via the GI tract (uranium that clears rapidly from the body causes relatively little 

dose). The FMPC urinalysis program began on or about the start of FMPC operations (1952­

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1953) and continued over the remaining operational period evaluated in this report, through 1989 

(ORAUT-TKBS-0017-5). 

•	 Routine in vivo analysis was performed with the frequency of monitoring based on the 

individual’s exposure potential and urine sampling results (more frequent for those workers 

working in high-exposure potential jobs). As indicated in the FMPC Internal TBD, lung counting 

became available at the FMPC in 1968 (in the form of the Mobile In Vivo Radiation Monitoring 

Laboratory) and continued over the remaining operational period evaluated in this report 

(ORAUT-TKBS-0017-5). 

Air Sampling Data 

Based on the large quantity of data archived in the form of data sheets, memos, reports, etc., it is clear 

that from the beginning of operations, FMPC maintained an aggressive air monitoring program. 

Routine air samples were taken in each plant and in each operational area. The air monitoring 

program was used as the primary means of controlling intakes (ORAUT-TKBS-0017-5). 

In the 1950s, both high and (primarily) low-volume general area and breathing zone air samples were 

collected (most for 3 to 30 minutes.) and counted for alpha contamination. A few sample records and 

claim file records indicate that some beta counts were performed (ORAUT-TKBS-0017-5). 

In the 1960s, the samples were counted for both alpha and beta activity. To determine action levels, 

the results were compared to the National Lead Concentration Guide (NCG) of 100 dpm m-3 (70 dpm 

m-3 was used as the MAC/NCG until the 1970s) (ORAUT-TKBS-0017-5). 

In 1986, Westinghouse Material Company of Ohio implemented a continuous air sampling program in 

FMPC production areas (ORAUT-TKBS-0017-5). 

Thorium air sampling was performed in areas of the FMPC where thorium was processed or stored. 

The Site Research Database (SRDB) contains limited air sampling data taken during thorium 

processing in Plant 1, Plant 2/3, Plant 6, Plant 8, Plant 9, the Pilot Plant, and the Developmental 

Machine Shop. A limited number of thorium samples were also found re-counted after a decay period 

to determine thoron levels. During the 1980s, a routine radon and thoron sampling program was 

established. Air monitoring data, specific to thorium operations, are being expanded through 

continuing historical data recovery efforts currently in progress for the technical basis document 

revision. New data, as discovered, will be added to the SRDB. 

Extensive, long-term air activity summary sheets that cover 15 or more years are available. These 

summary sheets indicate routine detectable air activity in all working areas of each plant. In addition, 

these summaries detail annual average exposures to workers without respiratory protection and 

average air activities associated with job assignments that required respirators (ORAUT-TKBS-0017­

5). 

Bioassay Sampling Data 

Starting in 1952, a urinalysis program was initiated at FMPC. The fundamental, primary bioassay 

during FMPC’s first 35 years of operation was urine analysis for uranium, reported in milligrams per 

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liter. Industrial physicians and industrial hygienists for National Lead of Ohio, Inc. performed and 

documented a number of studies to establish the uptake or maximum permissible body burden for 

workers exposed to uranium. Their initial study was based solely on heavy metal toxicological limits 

for kidney damage (ORAUT-TKBS-0017-5). 

Nearly all employees provided urine samples for uranium analysis (via fluorophotometry) at the time 

of their annual physicals. Workers who had assignments that were more likely to result in exposure 

were sampled weekly, monthly, or (at least) bimonthly. As discussed previously, these data are stored 

in the HIS-20 database and are available through DOE (ORAUT-TKBS-0017-5). 

Radionuclides other than uranium were analyzed on occasion throughout the years, predominantly by 

contract laboratories. During the early 1950s, several radon breath analyses were conducted for 

workers handling radium bearing materials. These data are important in demonstrating that workers 

that had the potential for exposure to radium bearing materials were in fact monitored. The breath 

radon data results for years 1952, 1953, and 1954 are available in the SRDB (SRDB Ref. IDs 3167, 

3191, 3193, and 3197). 

Fecal sampling has never been included in the routine bioassay program. However, since 1986, it has 

been recognized at FMPC that fecal sampling can provide useful information; fecal sampling has only 

been utilized at the site in special conditions. As a result, very little fecal sampling data applicable to 

the proposed class timeframe are available. 

In Vivo Analytical Data 

Although two lung counts were performed in 1965, lung counting did not become widely available at 

FMPC until 1968. Lung counting was performed by the Mobile In Vivo Radiation Monitoring 

Laboratory (MIVRML). Table 6.2 shows the number of measurements reported in the MIVRML data 

from the FMPC. Each result has been entered into a spreadsheet and is being analyzed to determine 

annualized lognormal distribution parameters for each measurement type. 

The mobile van visited FMPC routinely and performed lung counting based on worker internal 

exposure potential and worker urine sampling results. After lung counting became available, the 

annual reports to the Atomic Energy Commission listed the number of workers who exceeded 50% of 

the maximum permissible lung burden and the calculated annual doses to the lung in rem (ORAUTTKBS-0017-5). 

Table 6.2: Number of In Vivo Measurements Performed Annually at the FMPC 

(as reported in MIVRML) 

Year Uranium-235 Uranium Thorium Lead-212 Actinium-228 

1965 2 2 0 2 2 

1968 306 362 310 2 1 

1969 107 108 107 0 0 

1970 168 168 164 0 0 

1971 686 686 680 3 2 

1972 277 277 274 1 0 

1973 235 235 233 2 1 

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Table 6.2: Number of In Vivo Measurements Performed Annually at the FMPC 

(as reported in MIVRML) 

Year Uranium-235 Uranium Thorium Lead-212 Actinium-228 

1974 324 324 321 1 1 

1975 277 277 275 0 0 

1976 267 267 262 1 1 

1977 219 218 217 3 3 

1978 212 214 161 40 41 

1979 216 224 26 198 197 

1980 232 239 5 214 219 

1981 171 176 3 166 170 

1982 209 215 3 204 210 

1983 212 217 4 195 200 

1984 410 419 4 408 415 

1985 426 418 3 405 407 

1986 506 507 10 467 467 

1987 577 576 12 570 566 

1988 229 228 3 111 107 

1989 6 6 0 1 1 

Industrial Hygiene & Radiation Department Internal Deposition Action Level procedures dating from 

around 1970 suggest actions related to determining the percent maximum permissible lung burden of 

either uranium or thorium. Uranium-235 was detected primarily by emission of its 186 keV photon. 

Uranium-238 was calculated by measuring its thorium-234 progeny that was assumed to be in 

equilibrium with the uranium-238. Thorium-232 and thorium-228 activities were determined based 

on equilibrium assumptions and detection of their progeny (most likely actinium-228 for thorium-232, 

but lead-212 may have been used for assessment of both thorium isotopes). Thorium-230 is not 

readily detectable by in vivo measurements. There was apparently no attempt to detect transuranic 

contaminants using the Mobile In Vivo Radiation Monitoring Laboratory. In fact, the only 

determination made with the mobile van was to quantify the uranium lung burden in milligrams or 

micrograms of uranium, with the assumption of 1% enrichment and of occasional thorium lung 

burdens as indicated by some claim records. 

The results from the Mobile In Vivo Radiation Monitoring Laboratory were calibrated in μCi of 

uranium-235 and reported in milligram of uranium in the lung, which was translated to maximum 

permissible lung burden based on the assumed enrichment (generally 1%). The workers who had 

known exposures to high air concentrations, had high urine results, or were involved in an incident, 

were counted as the first priority each time the Mobile In Vivo Radiation Monitoring Laboratory 

visited the site. Other workers were counted based upon their job exposure potentials, as shown in 

Table 6-3. 

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Table 6-3 Typical MIVRML1

 Counting Schedule at the FMPC in the 1970s 

Labor Category Description In Vivo Counting Schedule 

All Chemical Operators Once per year 

Members of Project Labor Pool 

Mechanical Department Crafts 

During each MIVRML visit, 25% of the employees in these 

classifications were scheduled to be counted, and each 

worker would be counted at least once during a 2-year 

period. 

Mechanical Department Laborer 

Laundry Group 

Industrial Truck Operator 

Locomotive Operator 

Switchman 

Graphite Shop Machinist 

Machine Tool Operator 

Degreaser 

Crane Operator 

Stamper 

Plant 6 Laborer 

Furnace Operator Heater 

Mill Man 

Decontaminator 

Transportation Laborer 

Cafeteria 

Salaried personnel and workers in these classifications were 

not routinely counted because of low chronic exposure and 

low potential for unobserved acute exposures. 

Water Treatment Group 

Power Plant Group 

Heavy Equipment Operator 

Motor vehicle Operator 

Stores Warehouse Attendant 

Checker 

Industrial Mechanic 

Security Police Officer Porter 

Toolmaker 

Machine Set-up 

Tool Room Machinist 

Gauge Set-up 

Inspector 

Note: 

1

 Mobile In Vivo Radiation Monitoring Laboratory 

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6.2 FMPC External Monitoring Data 

The following information provides a general summary of the FMPC external monitoring program, as 

well as the types, quantity, and quality of the data that can be used for external dose reconstruction. 

Details regarding the various analyses used, the associated minimum detectable activities, the 

calibration procedures used, and details regarding missed doses are available in Technical Basis 

Document for the FMPC-Occupational External Dose (ORAUT-TKBS-0017-6). 

FMPC production workers have always used dosimeters, and as described in Section 6.0, these data 

are available. Table 6-4 shows the periods when male employees and female employees were and/or 

were not monitored. 

Table 6-4: FMPC Monitoring of Employees by Gender 

Timeframe Males Monitored Females Monitored 

1951-1960 YES NO 

1961-1968 YES YES 

1969-1978 YES NO 

1979-Present YES YES 

A Response to Dosimetry Assessment Fact Sheet states that female employees were not monitored 

during certain periods because the potential did not exist for them to exceed 10% of the quarterly 

standards since they were not production workers (Dugan 1981). 

FMPC used several types of personnel dosimeters throughout its operational period. There were also 

several changes in occupational and administrative exposure limits during that period, including 

dosimeter exchange periods. Table 6-5 summarizes information regarding the dosimeters and filters 

that were used, as well as the exchange frequencies. 

Table 6-5: FMPC Dosimeter Characteristics 

Years Dosimeter Filters Exchange Frequency 

1951-1954 Two-element film Open, Cadmium 1mm Weekly 

1954-1958 ORNL dosimeter Open, Copper, Cadmium, Plastic, Lead Biweekly 

1959-1985 ORNL dosimeter Open, Copper, Cadmium, Plastic, Lead Monthly 

1985-1989 Commercial Panasonic TLD Multiple Monthly 

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FMPC dosimetry technology was approximately equivalent to that used throughout the nuclear 

industry at the time. FMPC followed the Oak Ridge National Laboratory program for dosimeter 

design and calibration. The exception was FMPC’s lack of a requirement for neutron dosimetry. 

At the time of facility startup in 1951, occupational whole-body doses were controlled to 0.3 R/week 

and an extremity dose of 1.5 R/week. The annual limit for maximum whole-body dose for any oneyear period was 12 rem, and the annual extremity limit was 75 rem; both values had associated 

administrative limits that were fractions of the annual limits per calendar quarter. In 1955, the wholebody dose limits were reduced to 3 rem per 13 weeks, not to exceed 5 rem per year. It should be 

noted that the terms roentgen, rad, rem, and rep (roentgen-equivalent physical) often are used 

interchangeably, and this document makes the claimant-favorable assumption that they are considered 

equal. 

Since FMPC operation began in 1951, various radiation dose concepts and quantities have been used 

to measure and record occupational dose. A basis of comparison for dose reconstruction is the 

concept of Personal Dose Equivalent, Hp(d), where d identifies the depth (in mm) and represents the 

point of reference for dose in tissue. For penetrating radiation of significance to whole body dose (e.g. 

high-energy photons), d = 10 mm and is noted as Hp(10). For weakly penetrating radiation of 

significance to skin dose, d = 0.07 mm, and is noted as Hs(0.07). 

Extremity dosimetry at the FMPC involved the use of wrist dosimeters (rather than finger dosimeters) 

and the application of an appropriate correction factor. Early worker exposure records indicate that a 

factor of three was likely used as the correction factor (ORAUT-TKBS-0017-6). Documentation of 

the correction factor was not established until a study referenced in Technical Basis Document for the 

Fernald Environmental Management Project (FEMP) – Occupational External Dose determined that 

a factor of 2.06 times the wrist dosimeter value should be used to estimate the dose to the extremity 

(ORAUT-TKBS-0017-6). At the time of the study referenced in Technical Basis Document for the 

Fernald Environmental Management Project (FEMP) – Occupational External Dose, the wrist 

dosimeter being used was a Teflon disk embedded with CaSO4: Dy. However, records indicate that 

film had previously been used at FMPC. 

While using wrist-to-finger ratios to estimate extremity doses is not a particularly accurate practice, 

this approach was used at many DOE sites, with each site determining its own correction factor. 

Since the wrist dosimeter is worn on the outside of clothing and may be shielded by protective 

clothing on the extremities (e.g. gloves), using the wrist-to-finger ratios could over estimate dose by 

as much as 20%. Therefore, the recorded extremity doses should be claimant favorable and provide 

the best estimate of Hs(0.07) for individual monitored employees. 

Individual exposure records suggest an “open window” design for personnel monitoring devices that 

allowed both beta and photon radiation to reach the measuring element (film or thermoluminescent 

dosimeter (TLD)). Some DOE sites incorporated a security badge in the dosimeter holder that in 

some instances covered the open window of the dosimeter. However, FMPC did not cover the open 

window with its security credential (Dugan 1981), thus providing more accurate results than if the 

window had been covered. 

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There were several instances throughout FMPC when workers were subjected to high levels of 

radioactive material-bearing dust. This widespread source of contamination was a concern for proper 

use of personal dosimeters, and as a result, the dosimeters were enclosed in plastic bags to protect 

against dust contamination. The manner in which these contaminated dosimeters were handled was 

not identified. However, this should not inhibit dose reconstruction because the dosimeters were 

calibrated in plastic bags and no adjustments were made to the dosimeter results for either Hs(0.07) or 

Hp(10) (ORAUT-TKBS-0017-6). 

Because Hp(10) may be of predominant interest in dose reconstruction, uranium beta radiation can be 

considered insignificant. An evaluation of original recorded doses for FMPC workers based on these 

parameters should yield a good (best available) estimate of Hp(10). Where necessary, Hs (0.07) for 

those individual workers who came in direct contact with radiological source materials can also be 

obtained because open window results were recorded with no adjustments to those readings. 

7.0 Feasibility of Dose Reconstruction for the Proposed Class 

The feasibility determination for the proposed class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under this Act and rule, NIOSH must 

establish whether it has access to sufficient information either to estimate the maximum radiation dose 

for every type of cancer for which radiation doses are reconstructed that could have been incurred 

under plausible circumstances by any member of the class, or to estimate the radiation doses to 

members of the class more precisely than a maximum dose estimate. If NIOSH has access to 

sufficient information for either case, NIOSH would then determine that it was feasible to conduct 

dose reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class (identified in Section 9.0 of this report). If not, NIOSH systematically 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might allow NIOSH to estimate either the maximum doses that 

members of the class might have incurred, or more precise quantities that reflect the variability of 

exposures experienced by groups or individual members of the class (summarized in Section 7.6). 

This approach is discussed in OCAS’s SEC Petition Evaluation Internal Procedures (OCAS-PR-004) 

available at http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation 

Report examine: 

• the sufficiency and reliability of the available data - (Section 7.1) 

• the feasibility of reconstructing internal radiation doses - (Section 7.2) 

• the feasibility of reconstructing external radiation doses - (Section 7.3) 

• the bases for petition SEC-00046 as submitted by the petitioner - (Section 7.4) 

7.1 Pedigree of FMPC Data 

Examination of the primary internal and external monitoring data available for FMPC employees 

indicates that those data are of sufficient quality and quantity and adequately represent the range of 

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exposures associated with the work performed over the years identified in this evaluation. As 

discussed in detail in the FEMP Internal and External Technical Basis Documents, the monitoring 

approaches (targeting potential high-exposure work areas) and analytical techniques used to assess 

worker exposures at FMPC were commensurate with the state-of-the-art programs used at other DOE 

facilities (ORAUT-TKBS-0017-5 and ORAUT-TKBS-0017-6). 

Though data for specific non-uranium radionuclides are not as readily available, uranium has always 

been the dominant contributor to collective internal and external doses at FMPC. Generally small in 

comparison, doses from other radionuclides known to be present can be capped with the use of 

available gross alpha and beta results, use of conservative ratio assumptions, and the use of air 

sampling results which are available for every plant and operational area (see subsection 7.2). 

7.1.1 Internal Data Review 

Consistency of available internal monitoring data was checked by reviewing in vitro and in vivo 

analytical results. Based on conversations with FMPC data management personnel, essentially all of 

the uranium urinalysis laboratory results have been entered into the HIS-20 Database. As a result, 

most hard copy laboratory results have been placed in storage at the Dayton, Ohio Federal Records 

Center. However, some records from the mid to late 1950s are still present at FMPC and copies of 

these records are being supplied for inclusion into FMPC EEOICPA claimant files. Comparisons 

between analytical laboratory results available in four claimant files and those entered into the HIS-20 

Database were checked for internal data consistency. The results are presented in Table 7-1 as they 

appear in their respective sources (units, significant digits) (NLC, 1972; NLC, 1975; and Scudder, 

1971). 

Table 7-1: Uranium Urinalysis Data Comparison 

Employee Analytical Laboratory – Health and 

Safety Division Results HIS-20 Records 

Date Result (mg/l) Date Result (μgU/l) 

Employee 1 

12-14-1956 0.015 12-14-1956 15.00 

12-17-1956 0.021 12-17-1956 21.00 

03-11-1957 0.007 03-11-1957 7.00 

02-12-1958 0.010 02-12-1958 10.00 

04-30-1958 0.007 04-30-1958 7.00 

Employee 2 

03-13-1956 0.020 03-13-1956 20.00 

07-01-1957 0.021 07-01-1957 21.00 

07-19-1957 0.005 07-19-1957 5.00 

Employee 3 09-08-1955 0.068 09-08-1955 68.00 

12-29-1955 0.052 12-29-1955 52.00 

12-29-19551 0.008 12-29-19551 8.00 

02-20-1956 0.238 02-20-1956 238.00 

03-12-1956 0.066 03-12-1956 66.000 

06-29-1956 0.047 06-29-1956 47.00 

07-02-1956 0.035 07-02-1956 35.00 

08-07-1956 1.100 08-07-1956 1100.00 

08-08-1956 0.088 08-08-1956 88.00 

08-09-1956 0.032 08-09-1956 32.00 

08-10-1956 0.117 08-10-1956 117.00 

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Table 7-1: Uranium Urinalysis Data Comparison 

Employee Analytical Laboratory – Health and 

Safety Division Results HIS-20 Records 

Date Result (mg/l) Date Result (μgU/l) 

10-10-1956 0.060 10-10-1956 60.00 

10-11-1956 0.017 10-11-1956 17.00 

10-16-1956 0.040 10-16-1956 40.00 

10-30-1956 0.030 10-30-1956 30.00 

10-31-1956 0.003 10-31-1956 2.00 

11-01-1956 0.006 11-01-1956 6.00 

11-03-1956 0.067 11-03-1956 67.00 

11-04-1956 0.086 11-04-1956 86.00 

05-17-1957 0.065 05-17-1957 65.00 

07-01-1957 0.028 07-01-1957 28.00 

Employee 4 

10-11-1955 0.022 10-11-1955 22.00 

03-11-1957 0.019 03-11-1957 19.00 

02-03-1958 0.075 02-03-1958 75.00 

03-20-1958 0.024 03-20-1958 24.00 

Source for Comparison: NLC, 1972; NLC, 1975; and Scudder, 1971 

Note: 

1

 Second reading on 12-29-55 

As can be seen in the Table 7-1, there was only a single minor discrepancy (0.002 verses 0.003 mg/l 

result for Employee 3, 10-31-1956) between hardcopy analytical results and those results that are 

stored in the HIS-20 Database. 

In vivo data for FMPC employees are available and original hardcopy files serve as the source of this 

information. Because these data are still in original hardcopy (and handwritten) form, no consistency 

checks are applicable. 

7.1.2 External Data Review 

Information found in FMPC claimant files was used to check reporting consistency for external 

monitoring data. The same four files that were used for the internal data check were also used for the 

external monitoring check. Initially, external readings were read and recorded weekly; but during the 

39th week of 1956, the exchange and read frequency changed from weekly to bi-weekly. Beginning 

in 1959, external readings and recordings occurred on a monthly basis. Regardless of the exchange 

frequency, handwritten records were maintained for each monitored employee and for each badge 

reading. In addition, a summary radiation exposure record card, which presents annual and 

cumulative exposures measured, was maintained in each employee file. For comparison purposes of 

this evaluation, the available weekly and monthly monitoring results were compiled into annual doses 

so that the external doses could be easily compared to the summary radiation exposure record cards. 

Table 7-2 presents the results of an external monitoring data comparison performed between the two 

types of employee exposure record cards and the HIS-20 Database. As completed for the internal 

comparison, the data are shown and displayed as they occurred in their original sources with regards 

to units and significant figures. Aside from some apparent rounding when recording on the annual 

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and cumulative exposure record cards, the data sets agree (NLC, 1972; NLC, 1975; and Scudder, 

1971). 

Table 7-2: External Data Comparison: FMPC 

Employee Year 

Annual Totals Compiled 

from Weekly/Biweekly 

Exposure Records1

 (mr) 

Results from Annual 

Summary Exposure 

Records 1 (R) 

HIS – 20 Database Values2 

Annual Totals (rem) 

β γ γ β + γ DDE3 SDE,S4 

Employee 1 

1956 500 0 0 0.5 0.000 0.500 

1957 0 0 0 0 0.000 0.000 

1959 ­ - 0 0.1 0.000 0.100 

1964 - - 0 0.1 0.000 0.059 

1967 - - 0 0.2 0.000 0.181 

1975 - - 1.0 13.4 1.023 13.395 

1986 - - 0 0.1 0.000 0.084 

Employee 2 

1953 295 515 0.5 0.8 515 0.810 

1955 670 1170 1.2 1.8 1.17 1.84 

1959 - - 0.3 1.5 0.028 1.547 

1962 - - 0.6 2.8 0.565 2.815 

1966 - - 1.2 6.7 1.214 6.729 

1974 - - 1.4 3.2 1.409 3.238 

Employee 3 

1953 3,055 35 0 3.1 0.035 3.09 

1954 6,175 1,910 1.7 7.9 1.91 8.085 

1965 - - 3.2 10.7 3.247 10.717 

1971 - - 0.3 13.2 0.26 13.169 

1983 - - 0.4 9.0 0.408 9.017 

Employee 4 

1954 425 40 0 0.5 0.000 0.465 

1956 920 0 0 1.0 0 0.97 

1959 - - 0 1.8 0.020 1.835 

1969 - - 0.3 2.0 0.290 1.955 

1972 - - 0.8 13.6 0.845 13.612 

1982 - - 0.4 1.4 0.384 1.372 

Source for Comparison: NLC, 1972; NLC, 1975; and Scudder, 1971 

Notes: 

- Cards dated 1957 and earlier are currently still stored at FMPC and readily available for comparison as they have 

been supplied by FMPC for inclusion into individual claimant NOCTS files. Cards dating from 1958 and later 

have been shipped off by FMPC to be stored at the Dayton, Ohio Federal Records Center. At this time, data on 

the 1958 and later cards have not been included in this comparison. 

1 Results are from handwritten film badge exposure record cards that were filed for each monitored worker by the 

FMPC Analytical Department, Health and Safety Division. 

2 Like the original exposure record cards, database values are recorded per week prior to the 39th week of 1956, biweekly from that point through the end of 1958, and then monthly from that point on. 

3 Deep Dose Equivalent (γ)

4 Shallow Dose Equivalent, Skin (β + γ) 

An additional data consistency comparison was performed between data contained within the HIS-20 

Database and results recorded for individuals in several interoffice memoranda from the early to mid 

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1970s. Table 7-3 presents the results of this comparison (NLC, 1972; NLC, 1975; and Scudder, 

1971). 

Table 7-3: Comparison of Exposures Between Internal Correspondence and HIS-20 Database 

Employee Badge Period Reported in 

Memos 

Monthly Dose 

Reported in Memo (mrem) 

HIS – 20 Database 

Monthly Dose Values1

 (rem) 

β + γ γ DDE2 SDE, S3 

Employee 1 

01-06-1971 to 02-03-1971 1,325 19 0.019 1.310 

02-03-1971 to 03-03-1971 1,543 38 0.038 1.543 

03-03-1971 to 04-07-1971 1,959 73 0.072 1.958 

04-07-1971 to 05-05-1971 1,550 37 0.037 1.483 

Employee 2 

05-03-1972 to 05-31-1972 1,870 63 0.062 1.870 

05-31-1972 to 06-28-1972 1,625 73 0.073 1.626 

09-06-1972 to 10-04-1972 1,610 140 0.140 1.624 

10-04-1972 to 11-01-1972 1,390 139 0.137 1.391 

Employee 3 

02-05-1975 to 03-05-1975 1,300 120 0.120 1.328 

03-05-1975 to 04-02-1975 1,800 135 0.134 1.819 

04-02-1975 to 04-30-1975 1,425 111 0.111 1.447 

08-06-1975 to 09-03-1975 1,331 118 0.118 1.331 

Employee 4 

01-01-1975 to 02-05-1975 540 275 0.276 0.536 

03-05-1975 to 04-02-1975 430 225 0.228 0.431 

04-30-1975 to 05-28-1975 520 270 0.266 0.519 

08-06-1975 to 09-03-19754 630 330 0.029 0.078 

Source for Comparison: NLC, 1972; NLC, 1975; and Scudder, 1971 

Notes: 

1 Like the original exposure record cards, database values are recorded per week prior to the 39th week of 1956, biweekly from that point through the end of 1958, and then monthly from that point on. 

2 Deep Dose Equivalent (γ)

3 Shallow Dose Equivalent, Skin (β + γ)

4 Remarks in memo noted “dark spots, possible contamination”. NIOSH has not obtained information regarding 

how the final dose recorded in the database was determined. 

7.2 Internal Radiation Doses at FMPC 

The principal source of internal radiation doses for members of the proposed class was airborne 

uranium particulate material. This dust could be inhaled by individuals and then deposited in the 

respiratory tract. The dust would also settle on surfaces and become re-suspended in the air where it 

could again be inhaled or ingested by transfer from contaminated surfaces via hand to mouth. The 

majority of the exposures over the history of FMPC operations are considered to be chronic in nature. 

The bioassay program was established at the start of production. Bioassay results are available from 

the start of operations in 1952. 

In addition to uranium, which is the primary radionuclide contributing to internal dose at FMPC; 

exposure to various other radionuclides could have occurred. The other radionuclides of concern 

include thorium and the associated decay products, uranium decay products (including radium and the 

associated decay products), fission/activation products, and transuranics (recycled uranium 

contaminants). 

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The subsections below summarize the extent and limitations of information available for 

reconstructing the internal doses of members of the class. Most of the information summarized below 

is provided in greater detail in the individual TBDs and other document sources as described in 

Section 4.0. 

7.2.1 Process-Related Internal Doses at FMPC 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal doses of members of the proposed class. 

7.2.1.1 Urinalysis Information and Available Data 

NIOSH has access to thousands of urinalysis results representing the majority of the FMPC worker 

population at different times during the period covered by this report. FMPC began in vitro urinalysis 

using fluorophotometry in 1952. The practice at the facility was to collect a urine sample for uranium 

analysis from all employees at the time of the annual physicals, supplemented by frequent bioassay 

sampling of workers whose jobs required handling of uranium materials in the plant facilities. 

The primary purpose of this initial program, in conjunction with medical examinations, was to 

monitor for nephrotoxicity from uranium. However, workers in uranium production areas were also 

included in the urinalysis program to estimate internal dose, which was reported in percent and/or 

fraction of the maximum permissible body burden/maximum permissible lung burden. The 

monitoring frequency for employees ranged from a weekly to an annual basis. Nearly all employees 

provided urine samples for uranium analysis at the time of their annual physicals. Workers who had 

work assignments where exposure could be expected on a routine basis were sampled weekly, 

monthly, or at least bimonthly. 

Only a few thorium in vitro bioassay results were identified during NIOSH’s review for the time 

period evaluated in this report. Thorium was processed during 21 of the 35 year operational history of 

the FMPC (1954, 1955, 1960 to 1963, and 1964 to 1979). From 1968 to 1989, the Mobile In Vivo 

Measurement Laboratory from Y-12 provided lung count capabilities for thorium lung deposition. In 

the absence of specific bioassay data, thorium intakes are assigned on the basis of conservative 

assumptions and calculations based on measured air monitoring results. 

Exposures to uranium daughter products during the processing and/or handling of raffinates from 

chemical processing of uranium ores were derived through calculations based upon air monitoring 

data and isotopic constituents derived from silo waste sampling. 

Trace levels of contaminant radionuclides associated with recycled uranium work are also accounted 

for through application of a conservative ratio to uranium. The uranium urinalysis results used for 

dose reconstruction of uranium intake are used to obtain intakes of the recycled uranium contaminants 

through application of the analytical ratio. This default analysis is necessary, since bioassay for these 

isotopes were not available during the early years of operation. The associated methods are provided 

in Technical Basis Document for the Fernald Environmental Management Project (FEMP)-

Occupational Internal Dose (ORAUT-TKBS-0017-5). 

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Uranium compounds—in low enriched, depleted, and natural isotopic abundances— exhibiting all 

solubility types would have been present in various operations at FMPC during the site’s history 

(ORAUT-TKBS-0017-5). Therefore, types F, M, and S are considered in the dose reconstruction 

process and applied in a manner that is favorable to the claimant. 

7.2.1.2 Analysis of Coworker Bioassay Data 

Since nearly all FMPC workers were monitored for uranium in urine, no co-worker analysis has been 

deemed necessary for uranium intakes. However, there is an exception in the case of thorium dose 

reconstruction for workers exposed to thorium during the 1954 through 1955 and 1964 through 1968 

time periods (prior to in vivo lung counting technology introduction). By using the lung counting 

database from 1968 through 1979 with the associated air monitoring data during the same times 

(which are being expanded at the present time for further historical data recovery efforts), the air 

monitoring data in the 1954 through 1955 and 1964 through 1968 period will be used to bound the 

exposures during those periods in which no bioassay analyses are available for thorium. 

7.2.1.3 Other Types of Bioassay/Workplace Indicators 

As previously stated, the fundamental and primary bioassay for the first 35 years (1951 through 1986) 

of FMPC operational experience was urine analysis for uranium metal, reported in milligrams per 

liter. Radionuclides other than uranium have been analyzed on occasion through the years, 

predominantly by contract laboratories. Radon breath analyses taken in the early 1950s are available 

to bound occupational environmental exposures to FMPC workers from this source. The primary 

contract laboratory for FMPC in vitro analyses during the facility’s early years of operation was 

United States Testing Company in Richland, Washington. 

7.2.1.4 Airborne Levels 

NIOSH reviewed available process information for the entire operational period of the proposed class. 

Air monitoring programs were in place during this entire time period. These programs covered all 

operational areas and emphasized sample collection in process areas with higher potential for airborne 

contamination. In addition to general area airborne concentration levels, there are data available from 

job-specific breathing zone air sampling events. The number of available air sample results number in 

the thousands. Using process data, air sampling and bioassay results, and an assumed isotopic 

uranium source term (i.e., natural, enriched, and depleted uranium) when enrichment level is not 

recorded on the sample result, NIOSH can establish a maximum exposure scenario. Air monitoring 

data specific to thorium operations are currently being expanded through continuing historical data 

recovery efforts. The documented results, coupled with the recently recovered thorium lung count 

data, allow a default value to be established based on maximum credible assumptions. 

7.2.1.5 Other Radionuclides 

Uranium has always been the dominant contributor to collective internal dose at FMPC. However, 

during 21 years of the total operational period, thorium was processed in quantities totaling 

approximately 0.3% of the quantities of uranium processed. Air monitoring specifically identified for 

thorium operations, coupled with an extensive lung count database during 11 years of that period, 

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provides a basis for default intakes for workers who worked with these materials during the recorded 

periods of operation. 

Monitoring for other radionuclides has been performed on a limited basis. Both the relatively small 

concentrations and the difficulty of analyses contributed to the lack of documented data. From 1961 

until cessation of operations, a primary source of significant contaminants (including the production 

of other-than-normal uranium isotopes) that were introduced into FMPC plant systems were those 

associated with recycled uranium. Recycled uranium contained trace amounts of fission and 

activation products from reactor operations. 

The predominant recycled uranium and associated contaminants (plutonium, neptunium, and 

technetium) came from other DOE facilities, which had also either generated and/or received recycled 

uranium materials. Therefore, nearly all of the uranium in the DOE facilities contained recycled 

uranium contaminants to varying degrees (through being processed by the same equipment, blending 

with other materials to adjust the degree of enrichment, etc.). Of special note is a uranium recovery 

effort of tower ash, which had significantly elevated transuranic contaminant levels, from the Paducah 

Gaseous Diffusion Plant. This material was blended and processed with existing uranium inventories, 

basically doubling the calculated inventories of these contaminants in the FMPC facilities for a period 

of time. 

The fundamental conclusion in a variety of reports is that for dose reconstruction purposes, a 

conservative but reasonable default level of recycled uranium contaminants can be derived and 

applied as a percentage of the derived uranium intake for each of the four major contaminants. 

Analytical process information derived from a variety of sources allows calculation or interpolation of 

the levels of the predominant recycled uranium contaminants in the uranium materials received, 

processed, and handled at FMPC. Details regarding these calculations are contained in Technical 

Basis Document for the FMPC Occupational Internal Dose TBD (ORAUT-TKBS-0017-5). 

A short-term exposure potential occurred during the July 1952 to September 1958 handling and 

transfer of raffinates from Mallinckrodt Chemical Works to K-65 storage silos. Approximately 

13,000 55-gallon drums of raffinates were manually transferred to the silos. The isotopic inventories 

in the silos contained high percentage levels of radium-226. The attendant gaseous radon-222 decay 

product (and its associated progeny) produced a source of occupational exposure due to its emanation 

from the silos. Short term exposures to a few workers were possible during raffinate transfer 

operations during the 1950 time period. Few bioassay samples for radium were taken directly, 

although radon breath samples were taken during the early time period. Little radium intake is 

anticipated, although the breath samples will be used in conjunction with recorded air monitoring data 

to bound the worker intakes from this isotope. 

A potential for exposure to thoron (radon-220) and its progeny occurred in areas where thorium was 

processed or stored. Although limited thoron sampling was found in the Pilot Plant (samples found 

for the years of 1965, 1968, and 1977), Building 65 (samples found for the year of 1965), and the 

Developmental Machine Shop (samples found for the year of 1954), quarterly thoron sampling in 

occupied areas at the FMPC became routine starting in the mid 1980s (Weaver 1987; Weaver May, 

1987). By 1989, five “Working Level Monitors” were installed in areas where radon and thoron 

daughters were a concern, and thoron monitoring was performed upon entry into the thorium storage 

buildings, including Buildings 64, 65, and 68 (Walker, 1989). 

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Entry into the thorium storage areas, such as Building 64, 65, and 68, represent the worst case 

scenario at FMPC for thoron exposure since approximately 421 metric tons of thorium compounds (of 

the approximately 1,100 metric tons stored at the FMPC) were stored within these buildings. This 

represents a thorium quantity greater than that stored in any one area during the processing years 

(Parsons, 1993 Table 8-2; Dolan, 1988 Table 6; Mead 1985; Aas, 1986). Additionally, the thorium 

stored in these buildings was aged and would have been in an equilibrium condition with the thoron 

parent radionuclide radium-224. Many of the storage drums were also in a deteriorated condition 

(Parsons, 1993). Thus, the air samples taken upon entry into these thorium storage areas, or taken to 

monitor thorium repacking operations in 1989 and later, can be used to bound earlier exposures. 

7.2.2 Ambient Environmental Internal Radiation Doses at FMPC 

An evaluation of the ambient environmental internal radiation doses from plant releases of 

particulates/aerosols of uranium and the associated recycled uranium contaminants and thorium is not 

necessary because nearly all plant employees were monitored by routine air sampling and bioassay 

sampling. Thus, these doses are accounted for in the process-related internal dose evaluations. 

Ambient environmental internal radiation exposure at the FMPC could have occurred from radon and 

its progeny, emanating from several radium bearing material storage areas (the K-65 silos, Plant 1 

storage pad, and elevated Q-11 storage silos), and from thoron and its progeny, emanating from 

specific thorium production areas. 

Radon (and daughter) emissions from various storage areas have been studied—Condensed Final 

Report for Radon and Cigarette Smoking Exposure Assessment of Fernald Workers, The Fernald 

Dosimetry Reconstruction Project, Tasks 2 and 3, The Fernald Dosimetry Reconstruction Project, 

Task 6, and Uncertainty Analysis of Exposure to Radon Released from the Former Feed Materials 

Production Center— and information available from within these reports, in addition to recently 

retrieved radon breath analyses, can be utilized to bound occupational environmental exposures to 

FMPC workers from this source (Killough, Pinney, RAC 1995, and RAC 1998). The report written 

by Susan Pinney provides bounding exposure information for cases where no data are available for 

use (Pinney, 2004). 

As stated in the FMPC Environmental Monitoring Report for 1985, thoron (and daughter) emissions 

were monitored on a routine basis beginning in 1985 (Aas, 1986). In fact, 1985 was the first year that 

results from all isotopes of radon, including thoron (radon-220), were reported instead of just radon222. Because the inventory of thorium (the source of thoron emanation) that was being stored at the 

FMPC was the greatest during the mid to late 1980s, the results from the mid to late 1980s can be 

used to bound environmental exposures from thoron. 

7.2.3 Internal Dose Reconstruction Feasibility Conclusion 

NIOSH has established that it has access to sufficient internal dose information to either: (1) estimate 

the maximum internal radiation dose for every type of cancer for which radiation doses are 

reconstructed that could have been incurred under plausible circumstances by any member of the 

class; or (2) estimate the internal radiation doses to members of the class more precisely than a 

maximum dose estimate. 

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Recorded bioassay for uranium is extensive and sufficient for internal dose reconstruction. Thorium 

bioassay is not as well documented. However, with the addition of a database of in vivo bioassay 

(lung counting) and additional air sampling data currently being expanded, the air monitoring database 

is being strengthened through recent retrieval of additional field data, which will be used to ensure a 

claimant favorable dose reconstruction to represent maximum dose. 

Other radioisotopes were either: (1) contaminants present in recycled uranium, which may be 

accounted for adequately in dose reconstruction by applying conservative radionuclide ratios, or (2) 

specific isotopes of uranium and thorium progeny that resulted in short exposure duration to a limited 

number of workers. These possible intakes will be reconstructed by using air monitoring data and K65 silo isotopic inventories. 

The specific additional dose resulting from radon effluent from the K-65 silo can also be bounded by 

theoretical diffusion calculations. 

7.3 External Radiation Doses at FMPC 

The processes that generated the principal sources of external radiation dose are described in Section 5 

of this document. As documented in the Technical Basis Document for the Fernald Environmental 

Management Project – Occupational External Dose, the principal sources of external radiation 

included uranium and thorium compounds or metals and their radioactive progeny, especially the high 

energy beta emitter protactinium-234m and the gamma emitter radium-226. Beginning in 1961, 

recycled uranium brought trace levels of transuranics and other radionuclides into the facility. Low 

energy beta radiation from technetium-99, which is a fission product present in recycled uranium, is 

measured by the dosimeter as non-penetrating radiation. Neutron dose may have resulted from work 

around uranium compounds that included fluorine atoms, specifically green salts (uranium fluoride) 

and uranium hexafluoride. These fluorination materials were present in the Pilot Plant and Plant 4, as 

well as the Warehouse and Storage areas. 

7.3.1 Process-Related External Radiation Doses at FMPC 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related external doses of members of the proposed class. 

7.3.1.1 Radiation Exposure Environment 

The external dose received by workers at FMPC was a function of the physical location of the workers 

on the site, the process taking place, the type and quantities of material present, and the time spent in 

each location. Each worker with the potential to exceed 10% of the quarterly radiation limits 

(essential workers who occupied a radiation zone, controlled area, radiological area, or whatever 

designation was in use at the time) wore, as a minimum, a dosimeter that recorded exposure. The 

radiation contributing to external dose was primarily beta and photon, including X-rays. Neutron 

exposure was not monitored, nor was monitoring required by regulation. Neutron exposure, if any, 

was below the measurement threshold of the dosimeters in use up through the mid-1980s (Nuclear 

Track, Type A Emulsion film). 

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Beta and Photon Characterization 

The beta and photon radiations are well characterized in Technical Basis Document for the Fernald 

Environmental Management Project (FEMP) – Site Description and in the Technical Basis Document 

for the Fernald Environmental Management Project (FEMP)-Occupational External Dose and cited 

references (ORAUT-TKBS-0017-2 and ORAUT-TBKS-0017-6). Table 5-5, Default Photon Energies 

for FMPC Materials, summarizes the nominal photon energies for materials present at FMPC. The 

beta radiation spectrum ranges from low energy to high energy. Technetium-99, a contaminant in 

recycled uranium and many of the uranium and thorium progeny, contribute to the low energy beta 

spectrum. Protactinium-234m, a decay product of uranium-238, is a major contributor to high energy 

beta emissions and has a maximum beta energy of 2,281 keV. Penetrating dose rates have been 

documented to range from environmental levels (a few microrem per hour) to hundreds of mrem per 

hour in rarely occupied or inaccessible areas. A better estimate on the maximum penetrating dose rate 

in occupied areas is 10 to 20 mrem per hour. 

Neutron Field Characterization 

No measurements of the neutron energy spectra at FMPC have been discovered. Empirical 

knowledge documented in DOE Standard: Health Physics Manual of Good Practices for Uranium 

Facilities, indicate that the majority of neutron energy occurs in the 100 to 2,000 keV range (DOESTD-1136-2000). A few neutron dose equivalent rate measurements have been documented 

(ORAUT-TBKS-0017-6, page 18). For depleted uranium in green salt (uranium fluoride) form, the 

average rate was 0.076 mrem / hour. For low enriched uranium, ranging from 1.25% to 2% 

enrichment, the dose equivalent rate from green salt was 0.107 mrem per hour. 

7.3.1.2 History of Whole Body External Monitoring 

Historical data describing the external monitoring of exposures are documented from start-up to 

present in Technical Basis Document for the Fernald Environmental Management Project (FEMP)-

Occupational External Dose and cited references. From the beginning of operations, the site mirrored 

model radiation protection dosimetry programs established at other weapons complex sites. The Oak 

Ridge National Laboratory film dosimeter was used until late 1985 when it was replaced by the 

FMPC thermoluminescent dosimeter (TLD) system. In 1987, this dosimetry system, that is the 

dosimeter, reader, calibration, and record management practices, became the first TLD system 

certified by the DOE Laboratory Accreditation Program (DOELAP). This accreditation continues to 

be maintained through periodic recertification conducted by outside organizations. 

There were documented periods of time when certain classes of workers were not monitored based on 

the judgment of the radiation safety staff that they were unlikely to receive an external dose in excess 

of 10% of the quarterly limits. Because females did not work in production jobs between 1951 and 

1960, and then again between 1969 and 1978, only male employees were monitored for external dose. 

During other operational and post-operational periods, both male and female employees may have 

been monitored. Providing that the individuals maintained the same or very similar positions during 

the time periods in question, adequate data, preceding and following the given periods and/or 

preceding and following monitored exposures, are likely available to fill in any gaps for individuals 

with gaps in their exposures records. The default annual dose value for unmonitored employees has 

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been set at 500 mrem in Technical Basis Document for the Fernald Environmental Management 

Project (FEMP)-Occupational External Dose (ORAUT-TBKS-0017-6). 

7.3.1.3 History of Extremity Monitoring 

There is no site specific and complete history of the extremity monitoring program. However some 

data is available in FEMP External Dosimetry Program Development and in Technical Basis 

Document for the Fernald Environmental Management Project (FEMP)-Occupational External Dose 

(Cooper, 1998 and ORAUT-TBKS-0017-6). Extremity dosimetry was calculated using a wrist 

dosimeter measurement and a correction factor. Early worker exposure records provide some 

evidence that a correction factor of three may have been used. However, documentation of a 

correction factor was not established until a study described in the document titled FEMP External 

Dosimetry Program Development, determined that a factor of 2.06 times the wrist dosimeter value 

should be used to estimate the dose to the extremity. The wrist dosimeter in use at the time of the 

study was a Teflon disk embedded with CaSO4:Dy. However, records indicate that film previously 

had been used at the FMPC. Because the wrist dosimeter is worn outside of any protective clothing 

and worker extremities were shielded by protective clothing (e.g. gloves), the method of using a wristto-finger ratio may overestimate the extremity dose by as much as 20%. Therefore, the recorded 

extremity doses should be claimant favorable. 

7.3.1.4 Neutron Dosimetry Study and Dose Reconstruction 

Both the text and references of Technical Basis Document for the Fernald Environmental 

Management Project (FEMP)-Occupational External Dose contain the data used to develop a 

neutron-to-photon ratio to estimate neutron dose for workers in certain facilities where neutron dose 

was likely. In these cases, the neutron dose was a small fraction (nominally 10% to 20%) of the 

penetrating photon dose. The neutron-to-photon ratio used to establish neutron dose varies depending 

on the nominal uranium enrichment during the period of interest. For depleted uranium, the geometric 

mean of the ratio is 0.07 and the 95th percentile of the distribution is 0.17. For low enriched uranium, 

the geometric mean of the ratio is 0.10 and the 95th percentile of the distribution is 0.23. To simplify 

the dose reconstruction process and ensure claimant favorability, NIOSH assumes that the higher ratio 

value, which is associated with low enriched uranium, is used. These data, coupled with the 

individual’s dosimetry record, enable reconstruction of neutron dose. If a worker’s facility history 

cannot be determined from the individual’s records, then neutron dose will be assigned based on the 

photon dose. 

7.3.1.5 Dosimetry Records 

As is detailed above in Section 6.2, data and documents covering external dosimetry and related 

records covering the entire operational period of the FMPC are readily available. 

7.3.1.6 Application of Co-Worker Data for External Dose Reconstruction 

Since nearly all of the FMPC workers were monitored for external radiation, no co-worker studies 

have been performed. 

7.3.2 Ambient Environmental External Radiation Doses at FMPC 

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An evaluation of ambient environmental external radiation doses is not necessary because this dose is 

accounted for in the process-related external dose evaluation referred to in Section 7.3.1 of this 

evaluation. 

7.3.3 FMPC Occupational X-Ray Examinations 

As part of the requirements for FMPC employment, entrance, exit, and periodic physical examinations 

were performed on employees. These physical examinations typically included radiographic 

examinations of the lungs. For some employees, such as construction workers and laborers, lumbar 

spine X-rays may also have been taken. Photofluorographic X-rays are not known to have been 

performed at the FMPC (ORAUT-TKBS-0017-3, Section 3.2). 

Chest X-rays from the years 1952 to 1981 were performed annually for all employees. From 1981 

through 2002, employees over the age of 45 had annual chest X-rays while employees under 45 years 

of age were offered a chest X-ray every two years. The retake rate of the chest X-ray is estimated at 

15% (ORAUT-TKBS-0017-3, Section 3.2). 

7.3.4 External Dose Reconstruction 

Through September 14, 2006, 690 claims from FMPC workers had been submitted to NIOSH. Of 

those 690 claims, dose reconstructions have been completed for 619 claims. These claims cover the 

entire range of operation at FMPC with 93% of claims having external monitoring data available. 

There is an established protocol for assessing external exposure when performing dose reconstructions 

(these protocol steps are discussed in the following subsections): 

• Photon and Beta Dose 

• Neutron Dose 

• Unmonitored Individuals Working in Production Areas 

• Medical X-ray 

7.3.4.1 Photon and Beta Dose 

Each worker in a radiation zone, controlled area, radiological area, or whatever designation was in use 

at the time, as a minimum, wore a dosimeter which recorded radiation exposure. The radiation that 

was present at FMPC was primarily beta and photon, including X-rays. By considering the energy 

distribution and quantities, along with corrections provided in Section 6.3, Section 6.5, and Section 

6.8 of Technical Basis Document for the Fernald Environmental Management Project (FEMP)-

Occupational External Dose (which provides corrections for radiation energies less than 250 keV, and 

dosimeter bias and uncertainty), these considerations should account for any discrepancies in photon 

and beta radiation doses received at the site. 

The recommended procedure for missed photon and beta dose is to use a log normal distribution, with 

a median /central tendency equal to the Limit of Detection (LOD)/2 * (the number of zero 

measurements) and LOD * (the number of zero measurements) as the upper 95% estimate. 

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7.3.4.2 Neutron Dose 

Neutron exposure was not monitored, nor was monitoring required by regulation. The only likely 

sources of neutron exposure were those areas of the site where large quantities of fluorinated uranium 

compounds, such as uranium fluoride or uranium hexafluoride, were processed or stored. A neutronto-photon ratio has been developed to assign neutron dose to employees based on work location and 

measured penetrating photon dose (ORAUT-TKBS-0017-6, Section 6.3.5.1). 

7.3.4.3 Unmonitored Individuals Working in Production Areas 

Although female workers wore a combined security and dosimeter badge, during specific times, 

female employees at the FMPC were not routinely monitored. Female employees were not monitored 

during certain periods because it was determined that the potential did not exist for females to exceed 

10% of the quarterly standards, as they did not work in production areas. The guidance in Technical 

Basis Document for the Fernald Environmental Management Project (FEMP)-Occupational External 

Dose recommends assigning unmonitored workers 500 mrem per year as an upper bound limit for the 

years female workers were not monitored (1951 through 1960, and 1969 through 1978). There may 

have also been other circumstances, over the operational period of the FMPC, where either male or 

female workers may not have been monitored. Since the 500 mrem value is several times above the 

mean doses observed for monitored workers, this value could be adapted for all unmonitored workers 

for all years. 

7.3.4.4 Medical X-ray 

For dose reconstruction purposes, one annual chest X-ray procedure for each full or partial year of 

employment is assumed unless individual records suggest more frequent examinations. Hard copy 

records of X-ray exams, if performed, are included in the individual’s dose record provided by the 

DOE. 

A review of case records indicates that lumbar-spine X-rays were taken for some employees, but these 

X-rays may not have been for occupational or pre-employment purposes (ORAUT-TKBS-0017-3, 

Section 3.2). However, as a claimant-favorable assumption, if lumbar-spine X-ray records are 

identified in individual employee records, dose from lumbar-spine X-rays will be included in that 

individual’s dose reconstruction. In addition, for best estimate dose reconstruction cases, any X-ray 

performed on a worker should be assessed by the Dose Reconstructors to determine why the specific 

X-ray was performed. If it is determined that the X-ray was potentially performed as a condition of 

employment, dose from that procedure will be included (ORAUT-PROC-0061). 

To allow for dose reconstruction, Tables 3-13 through 3-19 of Technical Basis Document for the 

Fernald Environmental Management Project (FEMP) – Occupational Medical Dose, provide organ 

dose estimates for FMPC chest radiographs for the various years (1951 through 2004) of operation at 

the site. These doses vary by year depending on the type of equipment used and orientation of the 

subject, Posterior-Anterior or Lateral. The most claimant favorable dose may be selected when details 

of the actual examination are not known. 

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7.3.5 External Dose Reconstruction Feasibility Conclusion 

Recorded external dosimetry data is extensive and sufficient for external dose reconstruction. NIOSH 

has established that it has access to sufficient information to either: (1) estimate the maximum external 

radiation dose for every type of cancer for which radiation doses are reconstructed that could have 

been incurred under plausible circumstances by any member of the class; or (2) estimate the external 

radiation doses to members of the class more precisely than a maximum dose estimate. 

7.4 Evaluation of Petition Basis for SEC-00046 

The following subsections evaluate the assertions made on behalf of petition SEC-00046 for the 

FMPC. 

7.4.1 Evaluation of Major Topics Detailed in Petition SEC-00046 

The following major topics were discussed in petition SEC-00046. Italicized statements are from the 

petition; the comments that follow are from NIOSH. 

7.4.1.1 Lack of Monitoring for Recycled Uranium (RU) Contaminants 

SEC-00046 petitioner statements relating to the lack of monitoring for recycled uranium 

contaminants: 

o	 There was no monitoring for internal exposures for recycled uranium contaminants. 

o	 Prior to 1989, there were no recycled uranium contaminants that were reported in analysis. 

o	 In vivo counts were not performed frequently enough to be of significant value in transuranic dose 

reconstruction. 

o	 There was no monitoring to detect transuranic contaminants with the Mobile In-Vivo Radiation 

Monitoring Laboratory. 

o	 Before 1989, smears or air sampling filters were not analyzed specifically for plutonium, 

neptunium, or thorium isotopes. 

o	 Non-uranium urinalysis was not performed. 

o	 There was no monitoring for non-uranium radionuclides. 

Section 5.2.2 of Technical Basis Document for the Fernald Environmental Management Project 

(FEMP)-Occupational Internal Dose provides an approach to account for missed internal dose from 

unmonitored or undetected recycled uranium impurity activities. This approach determines the 

uranium intake, and then (for intakes occurring after 1961) adds a claimant-favorable ratio of recycled 

uranium impurity activities to that intake. Since the chemical form of the contaminant is unknown, 

the dose reconstructor is also directed to use the most claimant-favorable uranium solubility type for 

the target organ. 

For environmental internal dose reconstruction from recycled uranium contaminants, Table 4-10 of 

Technical Basis Document for the Fernald Environmental Management Project (FEMP)-

Occupational Environmental Dose, derived from historical site releases, provides a site-wide intake of 

each uranium and each non-uranium radionuclide by year from 1951 through 2002. 

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7.4.1.2 Lack of Monitoring for Thorium 

SEC-00046 petitioner statements relating to the lack of monitoring for thorium exposures: 

o	 In vitro bioassays for thorium were not performed. 

o	 Before 1989, smears or air sampling filters were not analyzed specifically for plutonium, 

neptunium, or thorium isotopes. 

o	 Non-uranium urinalysis was not performed. 

o	 There was no monitoring for non-uranium radionuclides. 

o	 Thorium exposures may have occurred in areas other than areas included in Table 5-16 of 

ORAUT-TKBS-0017-5 (Default Thorium Exposure). 

o	 How can a dose reconstruction be reasonably accurate when the exposure potential data is not 

inclusive for all production areas? 

o	 A question that was not asked during thorium process history reconstruction interviews was: What 

other plants processed thorium? [That seems so basic, if you’re reconstructing destroyed 

records]. 

o	 How is it claimant favorable to ignore a documented exposure? 

o	 The fact that no default exposure allowance was attributed to Plant 6 from January 1960 to July 

1963 indicates that it was not considered or included in the internal and external thorium 

exposure environment. 

The Fernald Environmental Management Project Site Profile default exposure approach is based on 

the review of air sampling results at the FMPC. Assumptions include not taking credit for standard 

respiratory protection factors, using an exposure period of 100 hours per year at an elevated airborne 

radioactivity level of 10 Maximum Allowable Concentration (MAC), as well as an exposure period of 

500 hours at a level of 0.1 MAC. The default thorium exposures are located in Table 5-16 of 

Technical Basis Document for the Fernald Environmental Management Project (FEMP) - 

Occupational Internal Dose (ORAUT-TKBS-0017-5). Table 5-16 includes only specific periods for 

the Pilot Plant, Plant 8, and Plant 9. If a work location is not clearly known for a worker, they are 

assumed to have been exposed to thorium at the times listed in Table 5-16. 

According to documents provided by the petitioner, as well as Technical Basis Document for the 

Fernald Environmental Management Project (FEMP) - Occupational Internal Dose, exposures to 

thorium may also have occurred in Plants 1, 4, and 6. These areas will be incorporated into Table 5­

16 of the Technical Basis Document for the Fernald Environmental Management Project (FEMP) - 

Occupational Internal Dose. 

The NIOSH position is that for any individual that indicates an exposure to thorium, the default 

intakes will be assigned. However, in light of new data, a more precise approach is being developed. 

As stated in Section 7.2, extensive MIVRML lung counting data are available from 1968 through 

1979, with the associated air monitoring data during the same times (which are being expanded at the 

present time from further historical data recovery efforts). The extensive air monitoring data in the 

1954 through 1955 and 1964 through1968 period will also be used to bound the exposures during 

those periods in which limited bioassay analyses are available for thorium. 

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7.4.1.3 Lack of Monitoring for Radium and Daughters 

SEC-00046: No records were found of any bioassay results for radium or daughter products during 

the time evaluated in this report. 

Starting in 1953, processing pitchblende ore and its associated waste resulted in exposures to radium 

and associated contaminants, including radon gas and its progeny. Radon breath analyses were 

conducted for workers handling radium bearing materials. Samples that were taken for the years 1952, 

1953, and 1954 are available in the SRDB (Ref. IDs 3167, 3191, 3193, and 3197). 

Section 5.2.4 of Technical Basis Document for the Fernald Environmental Management Project 

(FEMP) - Occupational Internal Dose (page 27 of 42) includes a maximizing approach to bound the 

exposure from K-65 silo operation. This method uses results of sampling performed in 1993. Also 

included in this section is a method to bound exposures from the radon and its daughters, which is 

based on the radon samples from October 29, 1953 (ORAUT-TKBS-0017-5). In addition to Section 

5.2.4 of Technical Basis Document for the Fernald Environmental Management Project (FEMP) - 

Occupational Internal Dose, The Pinney study, which estimated exposure to all FMPC workers, may 

also be used to bound the doses to workers when sampling results are not available (Pinney, 2004). 

7.4.1.4 No Personnel or Area Monitoring for Neutrons 

SEC-00046: There was no neutron dosimetry. 

The FMPC TBD makes reference to the FMPC policy that the facility did not require use of neutron 

dosimetry. However, it also states that large quantities of uranium fluoride and uranium hexafluoride 

were present onsite, creating the possibility of low-level neutron exposure via the alpha-neutron 

reaction from the uranium alpha particle and fluorine atoms. Section 6.3.5.2 of Technical Basis 

Document for the Fernald Environmental Management Project (FEMP) - Occupational External 

Dose addresses workplace neutron fields. The approach assumes claimant-favorable energies and 

uses the photon dose to account for neutrons by using the upper 95th percentile neutron-to-photon 

ratio of 0.23 (Technical Basis Document for the Fernald Environmental Management Project (FEMP) 

- Occupational External Dose, Table 6-10). 

7.4.2 Evaluation of Specific Petitioner Statements in SEC-00046 

This subsection presents specific affidavit statements made by workers on behalf of petition SEC00046. The italicized statements are from the petition; the comments that follow are from NIOSH. 

7.4.2.1 Respiratory Protection during K-65 Silo Processes 

SEC-00046: Doses (During K-65 Silo Processes) have repeatedly been based on airborne activity and 

have been calculated on the assumption that all workers were protected by respirators. 

Regardless of the TBD statement that respiratory protection was worn when K-65 Silo processes 

occurred, the maximizing approach to bounding K-65 silo exposure does not take credit for 

respiratory protection (ORAUT-TKBS-0017-5). 

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7.4.2.2 Internal Dose Not Assigned from Bioassay or Air Monitoring 

SEC-00046 petitioner statements relating to internal organ dose not assigned from uranium bioassay 

or air monitoring: 

o	 The uranium urinalyses that were performed were based on chemical toxicity and not radiological 

toxicity. Therefore, no radiological uranium urinalyses were performed. 

o	 Internal dosimetry was not introduced until 1986. Before DOE Order 5480.11 (89), bioassay data 

was not routinely used to estimate intake and internal organ dose. 

o	 There was no routine air monitoring used to establish internal intake and exposure estimates. 

Pre-1989 exposure control at FMPC was based on chemical toxicity and assumed that it would be 

sufficient for radiological control as well. A urinalysis program at FMPC was established from 1952 

on, with nearly all employees providing urine samples at their annual physicals. Workers with higher 

exposure potential were sampled weekly, monthly, or bi-monthly. The urine was analyzed for the 

total amount of elemental uranium in the sample by the fluorometric fusion process. Results of those 

analyses are given in units of milligram of uranium per liter, which can be converted to activity units 

using the specific activity of uranium. Before DOE Order 5480.11 (1989), there was no regulatory 

requirement to report organ doses from bioassay data. However, the data from the urinalysis sampling 

for uranium toxicity are available to perform the dose reconstructions. 

Since the beginning of operations, air sampling was performed extensively at FMPC. Routine air 

samples were taken in every plant and operational area. The FMPC air monitoring program was used 

to prevent workers from exceeding uranium intake limits associated with chemical toxicity, but was 

not typically used to establish worker intakes. Workers were required to submit routine urinalysis 

samples to verify that the work controls established by the air monitoring program were adequate. 

(ORAUT-TKBS-0017-5, Section 5.3.2) 

7.4.2.3 Fecal Sampling 

SEC-00046: Fecal sampling has never been part of the routine bioassay program. 

Fecal sampling was not typically used as part of routine monitoring at FMPC, but rather as part of a 

special study or incident investigation. Since uranium is present at varying levels in the environment, 

and thus is present in food and water, fecal sampling is less than reliable for routine monitoring. 

7.4.2.4 Falsification of Data 

SEC-00046: Air samples were manipulated to obtain desired readings and to give the appearance 

that radiation exposure levels were much lower than they actually were. 

A petitioner-supplied affidavit states that air sample results were manipulated. The applicant also 

submitted a document stating that the FMPC knowingly calculated effluent releases using a method 

which was flawed and grossly underestimated the releases. NIOSH could not find additional 

information corroborating that air monitoring was manipulated, nor do the FMPC technical basis 

documents specifically address this topic. While it is possible that air monitoring results were 

manipulated, this practice was unlikely to have routinely occurred, and since NIOSH will not be 

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relying on a single air sample result to estimate a worker’s intake (but rather a distribution of or 

compilation of multiple air dust measurements), it is unlikely that this practice would have a 

significant affect on an individual’s dose. 

7.5 Other Issues Relevant to the Petition Identified During the Evaluation 

Note to OCAS: This section will be developed from issues that come up from SC&A and the Board. 

7.6 Summary of Feasibility Findings for Petition SEC-00046 

This report evaluates the feasibility for completing dose reconstructions for employees at FMPC from 

January 1951 through December 1989. NIOSH found that the available monitoring records, process 

descriptions and source term data are sufficient to complete dose reconstructions for the proposed 

class of employees. 

Table 7-4 summarizes the results of the feasibility findings at FMPC for each exposure source during 

the time period January 1951 through December 1989. 

Table 7-4: Summary of Feasibility Findings for SEC-00046 

January 1951 through December 1989 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal X 

 - Uranium X 

 - Thorium X

 - Other radionuclides

 (e.g. POOS nuclides, radon, and thoron) 

X 

External X 

 - Gamma X 

 - Beta X 

 - Neutron X 

 - Occupational Medical x-ray X 

As of September 14, 2006, a total of 690 claims have been submitted to NIOSH for individuals who 

worked at FMPC during the years identified in the proposed class definition. Dose reconstructions 

have been completed for 619 individuals (90%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00046 

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not feasible to 

estimate with sufficient accuracy radiation doses for members of the class, NIOSH must also 

determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of class members when it has been established 

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that the class may have been exposed to radiation during a discrete incident likely to have involved 

levels of exposure similarly high to those occurring during nuclear criticality incidents. If the 

occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class, or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH has determined that internal and external doses can be estimated with sufficient accuracy 

using the available bioassay data, dosimetry data, and knowledge of the source term at FMPC. Our 

evaluation determined that it is feasible to estimate radiation dose for members of the proposed class 

with sufficient accuracy, based on the sum of information available from available resources. A 

modification of the class definition regarding health endangerment and minimum required 

employment periods, therefore, is not required. 

9.0 NIOSH-Proposed Class for Petition SEC-00046 

Based on its research, NIOSH accepted the petitioner-requested class to define a single class of 

employees for which NIOSH can estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all employees of DOE, DOE contractors, or subcontractors who were 

monitored or should have been monitored while working at all locations at the Feed Materials 

Production Center (FMPC), in Fernald, Ohio, also known as the Fernald Environmental Management 

Project (FEMP), from January 1, 1951 through December 31, 1989.The class was accepted because it 

encompasses all workers from the beginning of operations of the Pilot Plant until the time when the 

more stringent dose monitoring and reporting standards requirements of DOE Order 5480.11, 

Radiation Protection for Occupational Workers, governing the radiological control program went into 

effect (January 1, 1989). 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded accordingly (see Section 7.4). NIOSH has also reviewed 

available technical resources, and many other references, including the Site Research Database 

(SRDB), to locate information relevant to SEC-00046. Additionally, NIOSH reviewed its dose 

reconstruction database (the NIOSH OCAS Claims Tracking System (NOCTS)), to identify dose 

reconstructions under EEOICPA that might provide information relevant to the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. The guiding principle in conducting these dose reconstructions is to ensure 

that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be resolved to the advantage, rather than to 

the detriment, of the petitioners. When dose information is not available, or is very limited, NIOSH 

may use the highest reasonably possible radiation dose, based on reliable science, documented 

experience, and relevant data, to determine the feasibility of reconstructing the dose of an SEC 

petition class. NIOSH contends that it has complied with these standards of performance in 

determining that it would be feasible to reconstruct the dose for the class proposed for this petition. 

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10.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p. 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 USC §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation Program 

Act of 2000; as amended 

DG-8026, Health Physics Surveys in Uranium Recovery Facilities, Rev. 1, Regulatory Guide 8.30; 

U.S. Nuclear Regulatory Commission; May 2002; SRDB Ref ID: 13982 

DOE STD-1128-98, Guide of Good Practices for Occupational Radiological Protection in Plutonium 

Facilities, Section 6.2.3; Department of Energy Standard; February 2005; SRDB Ref ID: 22723 

DOE-STD-1136-2000, DOE Standard: Health Physics Manual of Good Practices for Uranium 

Facilities, Change Notice No. 3; December 2001; SRDB Ref ID: 4617 

EPA/ROD/R05-95/286, EPA Superfund Record of Decision; Environmental Protection Agency; 

March 1, 1995; SRDB Ref ID: not included in SRDB 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, Rev. 1; Office of 

Compensation Analysis and Support; Cincinnati, Ohio; August 2002; SRDB Ref ID: 22401 

OCAS-IG-002, Internal Dose Reconstruction Implementation Guideline, Rev. 0, National Institute for 

Occupational Safety and Health (NIOSH); Cincinnati, Ohio; August 2002; SRDB Ref ID: 22402 

ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related Diagnostic X-ray 

Procedures, Rev. 3 PC-1; December 21, 2005; SRDB Ref ID: 19422 

ORAUT-OTIB-0024, Estimation of Neutron Dose Rates from Alpha-Neutron reactions in Uranium 

and Thorium Compounds, Rev. 00; April 7, 2005; SRDB Ref ID: 19445 

OCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 0, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; September 23, 

2004 

ORAUT-PLAN-0014, Coworker Data Exposure Profile Development, Rev. 00; November 24, 2004 

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ORAUT-PROC-0060, Occupational Onsite Ambient Dose Reconstruction for DOE Sites, Rev. 01; 

June 28, 2006; not currently available in the SRDB 

ORAUT-PROC-0061, Occupational X-ray Dose Reconstruction for DOE Sites, Rev. 01; July 21, 

2006; not currently available in the SRDB 

ORAUT-TKBS-0017-1, Technical Basis Document for the Fernald Environmental 

Management Project (FEMP) – Introduction, Rev. 01; March 17, 2004; SRDB Ref ID: 19479 

ORAUT-TKBS-0017-2, Technical Basis Document for the Fernald Environmental 

Management Project (FEMP) – Site Description, Rev. 00; May 20, 2004; SRDB Ref ID: 19482 

ORAUT-TKBS-0017-3, Technical Basis Document for the Fernald Environmental 

Management Project (FEMP) – Occupational Medical Dose, Rev. 00; February 11, 2004; SRDB Ref 

ID: 19483 

ORAUT-TKBS-0017-4, Technical Basis Document for the Fernald Environmental 

Management Project (FEMP) – Occupational Environmental Dose, Rev. 00; April 6, 2004; SRBD 

Ref ID: 19484 

ORAUT-TKBS-0017-5, Technical Basis Document for the Fernald Environmental 

Management Project (FEMP) – Occupational Internal Dose, Rev. 00; May 28, 2004; SRDB Ref ID: 

19485 

ORAUT-TKBS-0017-6, Technical Basis Document for the Fernald Environmental Management 

Project (FEMP) – Occupational External Dose, Rev. 00; April 20, 2004; SRDB Ref ID: 19486 

Aas, 1986, Feed Materials Production Center Environmental Monitoring Annual Report for 1985; 

C. A. Aas, et al; May 30, 1986; SRDB Ref ID: 3553, page 417 

Advanced Sciences, Inc., date unknown, Remedial Investigation of the Feed Material Production 

Center—Part 1: Evaluation of Current Situation; SRDB Ref ID: 1858 

AEC, 1966, Uranium Hexafluoride Gas Release-Feed Materials Production Center, Fernald, OhioReport of Investigation Team; Atomic Energy Commission (AEC); March 16, 1966; SRDB Ref ID: 

3499 

Alvarez, 1984, Radiation Characterization and Radiological Equipment Evaluation at the Feed 

Materials Production Center, J. L. Alvarez, S. H. Daniel, L. O. Johnson, D. E. Martz, and B. L. Rich; 

May 1984; SRDB Ref ID: 3626 

Bonfer, 1988, Thorium- A Search of Available Records at the FMPC, Westinghouse internal 

memorandum from D. C. Bonfer to A. M. Schwartzman; D. C. Bonfer; November 15, 1988; SRDB 

Ref ID: 9012 

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Cavendish, 1970, Meeting Held on March 10, 1970, to Discuss Cutting Up of Thorium Derbies in 

Plant 6, National Lead of Ohio memo to files, ,J. H. Cavendish to Files, March 10, 1970; SRDB Ref 

ID:2660 

Cochran, 1987, Nuclear Weapons Databook, Volume III, U.S. Nuclear Warhead Facility Profiles, T. 

B. Cochran, et al; 1987; SRDB Ref ID: 27036 

Cooper, 1998, FEMP External Dosimetry Program Development History, Fernald Environmental 

Management Project, S. D. Cooper; January 22, 1998; SRDB Ref ID: 4330 and 12405 

DOE, Fernald Closure Project, website; last accessed September 12, 2006; 

http://www.fernald.gov/50th/fpf.htm 

Dolan, 1988, History of FEMP Radionuclide Discharges, Addendum to FMPC-2082, Special, UC-11; 

L.C. Dolan; December 1988; SRDB Ref ID: 2165 

Dugan, 1981, Response to Dosimetry Assessment Fact Sheet; written correspondence between T. A. 

Dugan and W. G. Tankersley; National Lead of Ohio, Inc.; September 11, 1981; SRDB Ref ID: 2901 

Hill, 1989, Historical Process Descriptions, FMPC Westinghouse internal document; C. A. Hill; 

1989: SRDB Ref ID: 4255 

Killough, 1999, Uncertainty Analysis of Exposure to Radon Released from the Former Feed Materials 

Production Center, No. 49; G. C. Killough and Schmidt; 1999; SRDB Ref ID: Currently not assigned 

Mead, 1985, History of the Operation of the Feed Materials Production Center; J. Mead, F. Savage, 

R. Fugate; 1985; SRDB Ref ID: 26097 

NLC, 1959, Sludge Furnace Alterations for Oxidation of Thorium Residues – Plant 6, Project 

Proposal; National Lead Company of Ohio; October 20, 1959; SECIS Ref ID: 9362, page 239 

NLC, 1972, Radiation Exposure Investigation for 1972, handwritten exposure records for various 

employees; National Lead Company of Ohio; 1975; SRDB Ref ID: 1395 

NLC, 1975, Radiation Exposure Investigation for 1975, handwritten exposure records for various 

employees; National Lead Company of Ohio; 1975; SRDB Ref ID: 1563 

Noyes, 1954, Committee Investigation Report of Thorium Blender Incident-March 15, 1954; J. H. 

Noyes, et al; April 5, 1954; SRDB Ref ID: 3635 

Parsons, 1993, Safety Analysis Report for the Warehoused Thorium Overpacking Building 65, 

Prepared for The Fernald Environmental Restoration Management Company With the U. S. 

Department of Energy Under Contract No. DE-AC05-92OR21972; Parsons; 1993; SRDB Ref ID: 

Pinney, 2004, Condensed Final Report for Radon and Cigarette Smoking Exposure Assessment of 

Fernald Workers; S. M. Pinney, et al; October 22, 2004; SRDB Ref ID: 26771 

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RAC, 1995, The Fernald Dosimetry Reconstruction Project, Tasks 2 and 3—Radionuclide Source 

Terms and Uncertainties, RAC Report No. CDC-5; Radiological Assessments Corporation (RAC); 

June 1995; SRDB Ref ID: 3767 

RAC, 1998, The Fernald Dosimetry Reconstruction Project, Task 6—Radiation Doses and Risk to 

Residents from FMPC Operations from 1951-1998, Volume 1, RAC Report No. 1-CDC-Fernald1998-FINAL; Radiological Assessment Corporation (RAC); September 1998; SRDB REF ID: 14175 

Scudder, 1971, Badges Receiving Over 1250 Beta Plus Gamma, badge readings for various time 

periods in 1971; C. E. Scudder; 1971; SRDB Ref ID: 1553 

Walker, 1989, Radiological Air Sampling Program and Air Sampling Philosophy; L. Scott Walker; 

February 10, 1989; SRDB Ref ID: 4152 

Weaver, 1987, Radon and Thoron Sampling Results, Westinghouse Materials Company of Ohio 

internal memorandum from A. S. Weaver to H. D. Christianson; April 1, 1987; SRDB Ref ID: 4185 

Weaver, May 1987, Radon and Thoron Sampling Results, May 1987, Westinghouse Materials 

Company of Ohio internal memorandum from A. S. Weaver to H. D. Christianson; May 29, 1987; 

SRDB Ref ID: 4248 

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